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HMDA & the Unlivable Mobile Home
Answer by David Dickinson, BOL Guru
Guru Bio

Question:  A person gets a loan to purchase a piece of property that contains a mobile home, but the mobile home is not livable and will be sold off so the loan purpose is to purchase the lot only. However, in addition to the purchase money, the customer's loan for the property which contains his residence (a mobile home) is rolled into the new loan. Is this considered a refinance for HMDA purposes?

Answer:  First, if the building on the property is not inhabitable, it is not a dwelling. If the mobile home will be sold and inhabited, it is a dwelling. Second, if the mobile home is inhabitable, this is a purchase (as purchase trumps refinance for HMDA reporting). If it is not inhabitable, this is a refinancing.

First published on BankersOnline.com 10/20/08









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