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#1961694 - 09/12/14 07:06 PM ECOA Valuations - Mobile Homes
A.B. Offline
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A.B.
Joined: Nov 2005
Posts: 165
KY
I would like to know what others are doing on consumer loans for a mobile home only that is not attached to real property. We currently use the online NADA Guide evaluation; therefore, I am of the opinion this would meet the guidelines of an "evaluation or appraisal" under the regulation and timing and delivery requirements apply. Our appraisal acknowledgment document refers to a "property address" and a mortgage. I would assume the property address is where the mobile home will be located but typically the property address refers to the address in the appraisal. And title liens are placed when it is only a mobile home in my state, not mortgages. I realize state law varies, however, I am curious what other institutions are using and whether their doc vendors have similar language and if so, whether a separate form was created just for mobile homes or if the current appraisal document is used?
Last edited by A.B.; 09/12/14 07:12 PM. Reason: Clarified property address
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#1961723 - 09/12/14 07:39 PM Re: ECOA Valuations - Mobile Homes A.B.
Jerod Moyer Offline
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Jerod Moyer
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Posts: 667
Sioux Falls, SD
The Commentary to 1002.14(b)(3) #3 excludes from the definition of valuation:

"Examples of documents that discuss the valuation of the applicant's property or may reflect its value but nonetheless are not "valuations" include but are not limited to... Publicly-available lists of valuations (such as published sales prices or mortgage amounts, tax assessments, and retail price ranges)." (i.e. NADA values)
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#1961817 - 09/12/14 10:09 PM Re: ECOA Valuations - Mobile Homes A.B.
A.B. Offline
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A.B.
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KY
Jerod - Thanks for your reply. I read that previously. I am interpreting under 14(b)(3)(1)(iv) 'A report generated by use of an automated valuation model to estimate the property's value' to include the NADA Value Report. Since the bank has to pay to access the report, enter specific information as it relates to the mobile home, region, etc. would this be considered publicy available as noted in the citation for exclusions? I considered publicly available to include valuation information that is available to view for free, whether it is online, paper, periodical, etc. For example, a county in Ky has a website published by the property valuation administrator. You can type in an address and access the PVA. I would include this under the exclusion provision you mentioned.

Additionally, the bank would not use the PVA amount listed to determine a loan to value amount but we would for the Value Report since it is based on a true estimated value.

I'm by no means saying my logic is right, it is just the due diligence I have done to this point that makes me think the NADA Value Report should be included. I am interested to see how others view this.
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#1961823 - 09/12/14 10:40 PM Re: ECOA Valuations - Mobile Homes A.B.
rlcarey Online
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rlcarey
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Galveston, TX
I have no real arguments, but some thoughts:

Do you just get a value out of a book and call it good (I know that is simplified, but it is for effect), or does the bank use that information and meld that with physical inspections, etc., to come up with a value eventually assigned by the bank? While all evaluations could contain some publicly available information, I think it really depends on what you do with it. All such supporting documentation is just part of the value evaluation.
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#1961832 - 09/12/14 11:20 PM Re: ECOA Valuations - Mobile Homes A.B.
A.B. Offline
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A.B.
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KY
All good thoughts. I'm not saying I'm right but just giving you my logic as I consider NADA to be an automation value model and because we get this estimated value and it is used to determine LTV requirements, it meets the condition of the regulation. If the bank's credit department (or lender) took it further and did collateral inspections, used the NADA estimated value to come up with a value assigned by the bank and had documentation supporting the value, I would consider that too to be covered by the regulation. I would consider that to fall in line under the Commentary listed at 14(b)(3)(1)(ii) 'A document prepared by the creditor's staff that assigns value to the property.'

I think the valuation examples in the Commentary makes for interesting conversation nonetheless.
Last edited by A.B.; 09/12/14 11:21 PM. Reason: Added last sentence
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#1961834 - 09/12/14 11:40 PM Re: ECOA Valuations - Mobile Homes A.B.
rlcarey Online
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Galveston, TX
If the bank's credit department (or lender) took it further and did collateral inspections,

You cannot tell me that your bank does mobile home lending sight unseen - or are you smile
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#1961838 - 09/13/14 12:39 AM Re: ECOA Valuations - Mobile Homes A.B.
A.B. Offline
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A.B.
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KY
Ha, well yes, they do, I was just using hypothetical in my example to show that it too could meet the citation in the example noted in my prior thread. Typically, a collateral inspection sheet would be completed.
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