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S-322
Reg. W-48
INTERPRETATION OF LAW OR REGULATION
(Copies to be sent to all Federal Reserve Banks)
September 10, 1941
TELEGRAM
Young - Boston
Sproul - New York
Williams - Philadelphia
Fleming - Cleveland
Leach - Richmond
McLarin - Atlanta

Young - Uhicago
Davis - St. Louis
Peyton - Minneapolis
Leedy - Kansas City
Gilbert - Dallas
Day - San Francisco

An inquiry has been received regarding the applicability
of section 6(a) of Regulation W to an extension of credit made ty
a builder covering the cost of building a home and secured by a
first lien on the real estate upon which the home is to be constructed.
The general principle applicable to these cases is that
the mortgage and the contract or contracts for the extension of
credit and the construction may be regarded as parts of a single
transaction and that the facts existing on the date of completion
may be used in determining the application of the regulation.

Con-

sequently, the Board is of the opinion that the extension of credit
may be regarded as secured ty a first lien on improved real estate
within the meaning of section 6(a).

The general principle is simi-

lar to that discussed in the second paragraph of W-43.




MORRILL