We are working on a project to finance primary dwelling purchase of mobile homes to be placed in a retirement communtiy park. There is no purchase of land (lot will be rented) so we know there is no RESPA, however we believe an Early TIL is required, also we are issuing a GFE to disclose fees that are required to complete purchase we will be offering both fixed and variable rate products. These homes will be MV900 filed. Can anyone give guidance to the respect of the early TIL and it's requirement and also the GFE.

The early TIL is only required when RESPA applies. And if RESPA doesn't apply, don't give a Good Faith Estimate. Use some other method of preliminary fee disclosure.

I guess I'm confused because I thought if the consumer credit over 53,000 is exempt unless the credit is secured by the personal property used or expected to be used as the consumers principal dwelling (mobile home). Understand about the GFE.

An early TIL, as Swiggles points out, is only required on RESPA loans. YOu have a consumer loan, so a TIL is required and it must be tested for HPML. In other words, it's subject to Reg Z, but not RESPA.

Light bulb goes off!!!!!! Get it, thinking way too hard!!
Thanks

Right....loans greater than $53,000 are exempt from Reg Z unless secured by real property or a manufactured home which will be the borrower's principal dwelling. But the early truth in lending disclosure only applies if RESPA applies, and RESPA doesn't apply if there is no real property. Your loans will only be secured by personal property. See 1026.19(a)

Hey it's Friday AND a Friday before a long weekend! Quit thinking so hard!