The titles have not been retired and there is a lien on the mobile home only by another lender.
If we take the land as collateral you would then assume we have a first on the land and a second lien on the MH. It is quite confusing.
If you do not take a specific security interest in the MH then you have no lien at all on the MH.
If we do not list the MH as collateral would we still need to provide all of the early disclosures and give the ROR?
I would assume if the MH was not pledged to another lender then we would have a first on the MH also and would need to escrow since we make HPML loans.
That is an incorrect assumption. As said earlier, unless you take a specific security interest in the MH you have no lien on it and it does not secure your loan.
The opinions expressed are mine and they are not to be taken as legal advice.