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#2043764 - 10/11/15 11:26 PM Mobile Homes & RESPA - FDIC Exam Manual?
Compliance Poster Offline
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Joined: Sep 2001
Posts: 413
On page V 3.4 of the FDIC's examination manual on RESPA, below, a graph is added to depict what RESPA-related loans are covered by the TRID disclosures. In the second column where it indicates what loans to continue using existing TIL and RESPA disclosures, it states "Chattel-secured mortgages (i.e., mortgages secured by a mobile home or by a dwelling that is not attached to real property, such as land) (subject to existing TIL disclosures, and not RESPA)." I thought that RESPA simply does not cover mobile homes not attached to land and wonder why it would be in the column at all. Would you please clear this up for me?

FDIC Examination Manual - RESPA

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TRID - TILA/RESPA Integrated Disclosures Rule
#2043768 - 10/12/15 01:22 PM Re: Mobile Homes & RESPA - FDIC Exam Manual? Compliance Poster
ahou Offline
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ahou
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Posts: 3,094
Chattel-secured mortgages (i.e., mortgages secured by a mobile home or by a dwelling that is not attached to real property, such as land) (subject to existing TIL disclosures, and not RESPA)

It says "and not RESPA" The MH only loan would be covered by Reg Z. The column is for both RESPA and Reg Z, as applicable.
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#2043927 - 10/13/15 05:31 PM Re: Mobile Homes & RESPA - FDIC Exam Manual? ahou
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Would this mean then that the list of homeowners counselling agencies, Affiliated Business Arrangement Disclosure, and the servicing disclosure statement would also not be required on mobile home-only loans as well?

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#2043931 - 10/13/15 05:41 PM Re: Mobile Homes & RESPA - FDIC Exam Manual? Compliance Poster
RR Joker Offline
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The Swamp
They never have been subject to those requirements.
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#2043982 - 10/13/15 07:47 PM Re: Mobile Homes & RESPA - FDIC Exam Manual? RR Joker
Ski Offline
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Joined: May 2003
Posts: 639
South Louisiana
Mobile homes only may not be subject to receiving the Homeowners Counseling List for RESPA, but if they are deemed High-Cost (HOEPA) loans under Reg. Z, you will have to give them the Homeowners Counseling List in order for them to get the counseling required to make the loan.

We have had 4 of these since January 2014 due to not passing the APR test.

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#2043993 - 10/13/15 08:21 PM Re: Mobile Homes & RESPA - FDIC Exam Manual? Compliance Poster
jmd Offline
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Joined: May 2002
Posts: 233
In a state where Mobile Homes in a park are considered "real property" under state law, would the same rules apply? The loans are secured by a mobile home only, no land.

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