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#1588976 - 08/08/11 04:59 PM Mobile Home
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
I know this answer is probably out there somewhere, I just can't find it. For a mobile home w/no dirt, is the ETIL required and therefore the loan cannot close in a minimum of seven days? Is ROR also required as it is the customer's primary dwelling and it is a refinance?
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#1588987 - 08/08/11 05:07 PM Re: Mobile Home Bec
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,953
Bloomington, IN
226.19(a)

In a mortgage transaction subject to the Real Estate Settlement Procedures Act (12 U.S.C. 2601 et seq.) that is secured by the consumerís dwelling,

ROR - depends if this is a cash out refinancing. Review the Commentary to 226.23.

HPML and HOEPA will apply if the applicable thresholds are met or exceeded.
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#1588995 - 08/08/11 05:15 PM Re: Mobile Home Dan Persfull
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,114
The Great White North
From reading what you provided, there is no ETIL requirement due to this note not being covered by RESPA.

The ROR would apply as this is a cash-out

Correct?
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#1588997 - 08/08/11 05:17 PM Re: Mobile Home Bec
Dan Persfull Offline
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Dan Persfull
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Posts: 46,953
Bloomington, IN
Correct.
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#1590182 - 08/10/11 05:21 PM Re: Mobile Home Dan Persfull
TJ-QC Offline
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If we are refinancing a loan secured by a mobile home and need to add money to the escrow bucket is that considered "new money" and would ROR apply? This is their primary home and there is no other cash-out.

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#1590203 - 08/10/11 05:33 PM Re: Mobile Home TJ-QC
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,953
Bloomington, IN
The escrow deposit would be part of the closing costs associated with the refinancing and would not be considered new money.
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The opinions expressed are mine and they are not to be taken as legal advice.

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