I believe this has been asked, but I cannot locate the response, so, apologies if this is a repeat:

We have a corporate borrower with a mortgage on the land only of a mobile home park - no dwellings of any sort collateralize the loan and it was not reported as HMDA.

The borrower has asked for additional funds under the future advance clause of the land only mortgage for the purpose of purchasing mobile homes that could be placed in any one of his many parks.

My thought is that this is not HMDA reportable as the loan is not secured by a dwelling and there are no home improvement funds involved.

Is this correct?

Correct.

Thank you again!!