After getting a new roof last year, the stone bank in Vineyard Haven that dates to the early 20th century may need to go back to its old look. But first the Martha’s Vineyard Commission will decide whether to conduct a post-construction review of the project, which replaced the original Spanish tiles with asphalt shingles in October.

Santander Bank, which owns the building, has said a clay-tile roof would cost $400,000, compared to the approximately $100,000 it spent on the asphalt shingles, The commission is deciding whether to review the project as a development of regional impact (DRI), since it involves changes to a building that is more than 100 years old.

Boston architect J. Williams Beal designed the distinctive fieldstone building for William Barry Owen, who made a fortune selling gramophones for the Victor Talking Machine Company and was the son of whaling captain Leander C. Owen. The building went up in 1905. The Spanish tiles were thought to have been installed soon after.

A town building permit for the new roof was issued last summer, but when work began, some Islanders were taken aback. Tisbury building inspector Ken Barwick finally referred the project to the MVC on Oct. 18, although work was allowed to continue.

“It just appears that it slipped by,” Island attorney Sean Murphy, representing Santander Bank, told the commission at a meeting on Thursday. He said Mr. Barwick should have referred the project to the MVC to begin with, but that the bank itself had acted appropriately. “They did what they were supposed to,” he said, urging the commission not to move forward with the review.

“They didn’t realize that something was amiss?” asked commissioner Kathy Newman, noting that residents were expressing concern as soon as the project began.

Mr. Murphy said he believed that by the time people noticed, the old tiles were already off the roof, and Hurricane Matthew was heading up the coast. “My understanding is they finished the job as quickly as possible,” he said. (The hurricane blew out to sea before reaching the Northeast.)

At their meeting meeting last Thursday, commissioners discussed whether they had the authority to review the project in the absence of a development permit. Mr. Barwick, who attended the meeting, said the town had not issued a stop-work order in the fall and that the building permit was still open. But commissioners agreed to seek legal counsel before voting on whether to review the project as a DRI.

“This is a substantial change to an important historic structure,” said commissioner Linda Sibley, who recalled the MVC reviewing other projects that should have been referred prior to completion. “I think we need to hold a public hearing on it unless our counsel tells us that we can’t.”

Commissioner Ben Robinson, who also sits on the Tisbury planning board, said the bank had yet to apply for a special permit that gives the planning board the ability to condition the project. “We’ve been waiting to see if there’s any negotiations with the bank that bear fruit,” he said. He also said Santander was partly to blame for the confusion. “There is some responsibility for the applicant to review the bylaws,” he said.

Santander Bank is a wholly owned subsidiary of the Santander Group, headquartered in Santander, Spain. No representatives from the bank attended the meeting.

The commission plans to continue the discussion on Feb. 2.

In other business, commissioners welcomed new member Michael Kim, Gov. Charlie Baker’s appointee. Mr. Kim is the first governor’s appointee to attend a commission meeting since 2014. Under its enabling legislation, the commission has five members appointed by the governor, although only one can vote. In previous years governor’s appointed members played an active role on the commission, but not so in recent years.

Mr. Kim is a Brookline architect who owns a cottage in Oak Bluffs. He said he hopes to be a regular presence at commission meetings.