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BankersOnline.com Forums Dodd-Frank Final Rules Discussions Ability to Repay/Qualified Mortgage Rule QM / ATR on Mobile Home with no Mortgage
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#2010172 - 04/24/15 05:23 PM QM / ATR on Mobile Home with no Mortgage
Web Offline
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Joined: May 2005
Posts: 316
We are doing a mobile home loan where we'll have a title to the mobile home, but there will not be a mortgage on the dirt the mobile home sits on. The borrower will use this has their primary residence and it will be a 3 year full payout loan. Am I correct that ATR and QM apply? Can I have a QM, when I don't have a mortgage? I feel like i'm over thinking this!

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Ability to Repay/Qualified Mortgage Rule
#2010177 - 04/24/15 05:31 PM Re: QM / ATR on Mobile Home with no Mortgage Web
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
Yes, it doesn't fall under "Respa" rules...strictly Z.

Referenced definition of 'dwelling' in Z:

(19) Dwelling means a residential structure that contains one to four units, whether or not that structure is attached to real property. The term includes an individual condominium unit, cooperative unit, mobile home, and trailer, if it is used as a residence.
Last edited by RR Joker; 04/24/15 05:32 PM.
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