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#1138870 - 03/03/09 03:55 PM flood determination and mobile homes
banker-12 Offline
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Do we need a flood determination for a loan secured with a mobile home that is not permanently attached to the land....title is not surrendered to real estate?

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#1138879 - 03/03/09 04:00 PM Re: flood determination and mobile homes banker-12
Dan Persfull Offline
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Dan Persfull
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Posts: 47,532
Bloomington, IN
If you are taking the MH as collateral, yes. And if it is in a SFHA then you must require flood insurance even if it means the owners have to anchor the MH in order to make it eligible for coverage.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1139042 - 03/03/09 05:59 PM Re: flood determination and mobile homes Dan Persfull
banker-12 Offline
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Joined: May 2007
Posts: 1,243
Does it matter if it is in a leased lot?

If we collect the fee for a consumer loan (not real estate), does it need to reflect it on the TIL as a POC.

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#1139045 - 03/03/09 06:06 PM Re: flood determination and mobile homes banker-12
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
No.

You do not have to disclose fees as POC for non RESPA loans. You only have to show the itemization of the amount financed. However the portion for life of loan monitoring would be a prepaid finance charge and would have to be reflected in the APR.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1139094 - 03/03/09 07:01 PM Re: flood determination and mobile homes banker-12
RR Joker Offline
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RR Joker
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The Swamp
Originally Posted By: banker-12
Do we need a flood determination for a loan secured with a mobile home that is not permanently attached to the land....title is not surrendered to real estate?


I get a little mixed feelings when I read this. Surrendering title and permanently affixed are two separate issues.

If the mobilehome is on piers and "tied down" or "anchored", it's considered permanently affixed...that does not mean it can't be moved in the future, it's just considered more "stable" at this point.
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