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#2294516 - 03/07/24 07:33 PM Manufactured Home Community
swiggles Offline
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swiggles
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I finally have one of these! I have a loan to purchase a mobile home park that currently has only one space occupied. But I'm not sure what to select for the Manufactured Home Secured Property type or the Manufactured Home Land Property Type. I don't understand what the below citation is telling me. Please help. Thank you.

(29) If the dwelling related to the property identified in paragraph (a)(9) of this section is a manufactured home and not a multifamily dwelling, whether the covered loan is, or in the case of an application would have been, secured by a manufactured home and land, or by a manufactured home and not land.

2. Manufactured home community. A manufactured home community that is a multifamily dwelling is not considered a manufactured home for purposes of § 1003.4(a)(29).

(30) If the dwelling related to the property identified in paragraph (a)(9) of this section is a manufactured home and not a multifamily dwelling, whether the applicant or borrower:

4. Manufactured home community. A manufactured home community that is a multifamily dwelling is not considered a manufactured home for purposes of § 1003.4(a)(30).
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#2294518 - 03/07/24 07:57 PM Re: Manufactured Home Community swiggles
Truffle Royale Offline

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Are you sure these aren't Park homes? They're not reportable.

The secured property type is going to depend on whether the buyer gets just the home or the home and the land it sits on.
You have two choices under each of owned or leasehold as far as land property type.

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#2294523 - 03/07/24 09:00 PM Re: Manufactured Home Community Truffle Royale
swiggles Offline
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My borrower purchased a mobile home park. Doesn't the below citation tell me that it IS reportable?
 
(f) Dwelling means a residential structure, whether or not attached to real property. The term includes but is not limited to a detached home, an individual condominium or cooperative unit, a manufactured home or other factory-built home, or a multifamily residential structure or community.

Official Interpretation (Commentary)

2. Multifamily residential structures and communities.
A dwelling also includes a multifamily residential structure or community such as an apartment, condominium, cooperative building or housing complex, or a manufactured home community.

A loan related to a manufactured home community is secured by a dwelling for purposes of § 1003.2(f) even if it is not secured by any individual manufactured homes, but only by the land that constitutes the manufactured home community including sites for manufactured homes.
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#2294524 - 03/07/24 09:08 PM Re: Manufactured Home Community swiggles
Inherent_Risk Offline
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If you're collateral is the mobile home community itself, then it is a multifamily dwelling and those would be NA. How many pads are occupied isn't going to matter for HMDA. Units would be based on number of pads. If your collateral is just a manufactured home, then it will depend on ownership of the land.

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#2294528 - 03/07/24 09:21 PM Re: Manufactured Home Community swiggles
swiggles Offline
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swiggles
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So you're saying that the two data points I mentioned in my original post are "n/a"?? Because the land is considered to be "multi-family?" Can you give me a citation? I can't find it.

But so, the construction method would still be: Manufactured Home?
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#2294531 - 03/07/24 09:41 PM Re: Manufactured Home Community swiggles
Inherent_Risk Offline
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You gave most of the relevant citations. They all say multifamily, and everything about MHCs is located under headings that say multifamily. Only other citation is this (relating to pads instead of homes on the site)

2. Manufactured home community. For an application or covered loan secured by a manufactured home community, the financial institution should include in the number of individual dwelling units the total number of manufactured home sites that secure the loan and are available for occupancy, regardless of whether the sites are currently occupied or have manufactured homes currently attached. A financial institution may include in the number of individual dwelling units other units such as recreational vehicle pads, manager apartments, rental apartments, site-built homes or other rentable space that are ancillary to the operation of the secured property if it considers such units under its underwriting guidelines or the guidelines of an investor, or if it tracks the number of such units for its own internal purposes.

Does your community have less than 5 pads? I've never run into that, and I'm not 100% sure whether it would be reportable or how. If it has more than 4 pads, then it is considered multifamily, and those answers are NA.

Edit: And yes, construction type would be Manufactured. You'll get a quality edit.
Last edited by Inherent_Risk; 03/07/24 09:42 PM.
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#2294532 - 03/07/24 09:47 PM Re: Manufactured Home Community swiggles
swiggles Offline
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swiggles
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Thanks, Inherent Risk. No. The property for my loan only has 4 pads. If you don't know, does anyone else....pleeeeez?!!
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#2294557 - 03/08/24 03:26 PM Re: Manufactured Home Community swiggles
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
I have never ran into this either (less than 5 units in the MHC) but my opinion is as follows.

Construction Method - Code 2
Manufactured Home Information - Code 1 (the pad is considered a manufactured home and the loan is secured by the pad and the land the pad is located on)
Manufactured Home Land Property Interest - Code 1
Total Units - 4
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#2294558 - 03/08/24 03:54 PM Re: Manufactured Home Community swiggles
swiggles Offline
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swiggles
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I can take this one step further. This borrower does not plan to use this land a manufactured home park....will convert to RV park....8 sites instead of 4. Would you report it because the borrower purchased it as a manufactured home park?
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#2294580 - 03/08/24 08:42 PM Re: Manufactured Home Community swiggles
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
You report based on the property type at the time of the transaction.

See Q&A 1 - Construction and Construction/Permanent Transactions. Your situation would be similar to it. Your borrower is purchasing a 4 unit manufactured housing community to convert (reconstruct) it into a RV park.

https://www.consumerfinance.gov/com...ments/home-mortgage-disclosure-act-faqs/
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#2294590 - 03/08/24 11:39 PM Re: Manufactured Home Community swiggles
swiggles Offline
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swiggles
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Bless you, Dan!!....and everyone else!!!
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