If a loan for under $50,000 is secured by a manufactured home with an active title and the real estate that it sits on, is it considered personal property under 1026.32(a)(1)(i)(B) for the purpose of applying the 8.5% spread over the APOR to determine HOEPA status or would the 6.5% spread apply?

We have the same situation with the same question, any replies?

I don't know about anyone else, but I have always read this "Titled as Personal Property" as meaning a mobile/manufactured home ONLY; NO real estate involved.

Thanks.