They reference that manufactured home uses the same definition as found in 24 CFR 3280.2, see below, but give no indication (that I've found so far) on what a 'mobile home' is. Given that a manufactured home can be one piece, does it sound like what they mean by mobile home would be a recreational vehicle used as a PR??

Manufactured home means a structure, transportable in one or more sections, which in the traveling mode is 8 body feet or more in width or 40 body feet or more in length or which when erected on-site is 320 or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained in the structure. This term includes all structures that meet the above requirements except the size requirements and with respect to which the manufacturer voluntarily files a certification pursuant to § 3282.13 of this chapter and complies with the construction and safety standards set forth in this part 3280. The term does not include any self-propelled recreational vehicle. Calculations used to determine the number of square feet in a structure will include the total of square feet for each transportable section comprising the completed structure and will be based on the structure's exterior dimensions measured at the largest horizontal projections when erected on site. These dimensions will include all expandable rooms, cabinets, and other projections containing interior space, but do not include bay windows. Nothing in this definition should be interpreted to mean that a manufactured home necessarily meets the requirements of HUD's Minimum Property Standards (HUD Handbook 4900.1) or that it is automatically eligible for financing under 12 U.S.C. 1709(b).

"The term does not include any self-propelled recreational vehicle."

But my problem is this.

They use the exemptions:

• transactions secured by a new manufactured home
• transactions secured by a mobile home, boat, or trailer


but only define manufactured.

Around here, we consider them two different things. A mobile home being titled property and manufactured is not.

They have to be meaning an RV type (self propelled), but I think they should have defined it if they are going to use it.

the closest I can find that they come to defining "mobile home" is

Paragraph 34.203(b)(3).
1. Secured by a mobile home. For purposes of the exemption in § 34.203(b)(3), a mobile
home does not include a manufactured home, as defined in § 34.203(a)(2).


Well....that's spectacularly unhelpful.

Exactly.

Everything I've read seems to indicate that "manufactured home" includes "mobile homes" in that they both have an undercarriage for delivery and when placed on site the wheels are removed, but the undercarriage remains.

Based on a comment in Regulation B, the term "mobile home" is outdated and no longer used in the manufactured home industry.

I have to wonder if, in using "mobile home" in this instance, they actually mean "recreational vehicle"?

But then again.... who knows?

Yes...that's the only thing they can be meaning! I'd rather than just said RV or something tho! LOL

South Georgia still has a 'mobile home' mentalilty!

Has anyone figured out the bulk sale issue on figuring out what an individual sales price was on one property involved? All I can think of would be the stated amount on the tax record.

An appraiser trade association stated that an appraiser’s expertise is important in valuing
properties that are part of a bulk sale. No other commenters commented on this question. In
view of the value that appraisers can add in valuing properties as part of a bulk sale, and in the
absence of requests or suggestions for additional guidance, the Agencies are adopting the rule as
90
proposed with no additional provisions or clarifications regarding the purchase price of
properties purchased in bulk sales.

RR - where is your quote coming from? I don't recall bulk sales being discussed.

Andy, it's on page 89 of Z.

I wondered, because it's not unusual for an investor to buy 50 - 100 properties in one fell swoop and then either hold as rentals, or sell some of them.

The discussion just seemed vague to me.

The power of the comment letter. Only an appraisal group commented and said appraisals are important which really didn't answer the CFPB question of how to identify the price the seller paid. The only statement is "The Agencies understand that, in bulk sales, a sales price might be assigned to individual properties for tax or accounting reasons..."

This may be a matter for clarification later based on the CFPBs read of the deal.

I found something about mobile homes today.

The NADA website says a "mobile home is a factory-built home that is 1) built before June 15, 1976, and 2) not built to a uniform construction code."

Do you think it would be advisable to use this definition when reading these new rules where the term mobile home is used?

Do you think it would be advisable to use this definition when reading these new rules where the term mobile home is used?

Where is the term "mobile home" used in the new Regulation B rules? They removed it.

As far as Regulation Z, if it is not part of the titled land and is separately titled, I think you are safe to treat it as either a mobile home or manufactured home without further definition.

So for my sanity's sake:

New manufactured (or mobile)homes regardless of whether or not they are also secured by land are not subject to the Reg. Z HPML appraisal rules.

Not new manufactured (or mobile)homes that are attached to property are subject to the new HPML appraisal rules.

Not new manufactured (or mobile) homes not attached to land (personal property) are never subject to the HPML appraisal rules.

Thanks!

Is that right?

Based on my interpretation, I have defined 'mobile home' as a self propelled mobile home, such as an RV. I think you have to define it differently. The definition of a manufactured home as found in 12 CFR 3280.2 describes a home used as a dwelling with or without a permanent foundation when connected to utilities.

Because there is an addtional proposal to potentially exempt/exclude existing manufactured homes, I feel they must be making a distinction between a 'mobile' and a 'manufactured' home. Since what we think of as a 'mobile' home, fits the definition of 'manufactured' homes, I truly believe their intention on 'mobile' was truly...mobile...not how it's titled.