I am in the process of training my staff on HMDA and just as I thought I had all my ducks in a row, along comes the confusion, once again, on Manufactured homes vs. 1-4 family. Specifics - Construction loan termed out reported as purchase on LAR. However, the home was a modular home purchased and built in Canada. It was delivered onsite in 4 pieces and put together, siding, inner walls, foundation, etc, etc. I have read all the regs and the comment 203.2(i) referring to HUD and still cannot come up with a clarification to this question. I am in conflict with my higher archy and would like help. My feeling is that the home is not "essentially ready for occupancy upon leaving the factory" therefore, it is not considered a manuf. home. Can anyone please give any other info besides what I have already read? Thank you for reading and hopefully taking the time to answer.

If it were manufactured in the US, the simplest way to determine if it was MH would be to look for the HUD inspection sticker.

Since it was not, and since you stated that the modular home required assembly at the site (and was not "ready for occupancy upon leaving the factory"), I would say this is not MH.

If it is a true modular home then it will fall under the manufactured housing classification. However some people confuse the terms "modular" and "prefabricated".

It sounds like you have a prefabricated home and it would not fall under the manufactured housing definition IMO.

You can always fall back on this out from page A-1 of the GIR:

b. If you cannot determine (despite reasonable efforts to find out) whether the loan or application relates to a manufactured home, use Code 1.

Thanks for your answers and those were my thoughts. I just need to be more convincing to others. I think that what we will do it report as 1-4 family because we are not able to make a clear decision. However, if we were to report it as a MH even though we couldn't determine, is it going to be wrong? I am unsure.

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However, if we were to report it as a MH even though we couldn't determine, is it going to be wrong? I am unsure.

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Because these are new reporting requirements and have not been examined yet I'm not sure either, but IMO as long as you can document why you thought it met the MH definitions you would be OK.

FWIW, if I was unsure I would use Code 1.

You could also try checking the appraisal. The appraisals we get will usually indicate whether or not it is a manufactured home.

Quote from HDMA: Getting It Right:

"Definition of a manufactured home: The HUD code requires generally that housing be essentially ready for occupancy upon leaving the factory and being transported to a building site... Other factory built homes, such as panelized and pre-cut homes, generally do not mee the HUD code because they require a significant amount of construction on site before they are ready for occupancy."

(Page D-6)

Hope this helps.