We do loans to MH dealers to finance the purchase of MH's for them to sell.

We currently do not report these as we feel they are inventory and are not inhabitable while on the dealer lot.

I currently have an auditor telling me they should be reported as purchases.

Who is corret on this one?

Regulation citation would be awesome.

I am digging in the GIR, FAQ's etc as I type this.

You're kidding right? So you are going to report three hundred mobile homes purchased located at the same address over the course of a year (assuming this is a high volume dealer). Hopefully, the dealer is in a low income census tract - think of the CRA credit you are going to get.

Tell this auditor to go crawl back under the rock he has been hiding under for the last 15 years.

Since this a pretty wacko take on the regulation, you probably won't find it specifically addressed. I would suggest that you make a joint call to the HMDA Helpline and I am sure they can set him straight.

Perhaps you could direct this auditor to the OCC book on floor plan and indirect lending. There is obviously a large knowledge gap here.