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#2049143 - 11/10/15 09:32 PM Mobile Home loan
Catm1991 Offline
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Joined: Jul 2014
Posts: 194
MO
If we have a loan to purchase a Mobile Home wouldn't this be HMDA reportable? It's coded as an installment loan, not a real estate loan but he is purchasing it to put on his father's land and will be his primary residence.

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#2049145 - 11/10/15 09:34 PM Re: Mobile Home loan Catm1991
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Definition of dwelling under current HMDA rules:

Dwelling means a residential structure (whether or not attached to real property) located in a state of the United States of America, the District of Columbia, or the Commonwealth of Puerto Rico. The term includes an individual condominium unit, cooperative unit, or mobile or manufactured home.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2049148 - 11/10/15 09:36 PM Re: Mobile Home loan Catm1991
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
The definition of a dwelling in 1003.2 includes a mobile home, therefore the purchase of a mobile would be reportable if the loan will be secured by a dwelling.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2049170 - 11/10/15 10:10 PM Re: Mobile Home loan Catm1991
Catm1991 Offline
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Joined: Jul 2014
Posts: 194
MO
I thought it would. We are taking the mobile home as collateral. We don't have land or anything as collateral with it, but customer did mention he was going to put it on his dad's land.

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#2049204 - 11/11/15 02:11 PM Re: Mobile Home loan Catm1991
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Land is not a determining factor for HMDA reportability. If the loan is to purchase, refinance or improve a dwelling the loan is reportable.

From KB's cite:

Dwelling means a residential structure (whether or not attached to real property)
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2050982 - 11/23/15 07:17 PM Re: Mobile Home loan Catm1991
Still Learning Offline
New Poster
Joined: Jan 2013
Posts: 24
Texas
What would you use as the property location? My borrower purchased 6 mobile homes to rent out, that are not tied to real property. I am assuming it will be where he keeps them until they are rented/sold.
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T.S.

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#2051942 - 12/01/15 09:47 PM Re: Mobile Home loan Still Learning
Frank Ernest Offline
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Joined: Nov 2004
Posts: 138
Somewhere on a beach
If they provide the address of where they will be kept until they are sold, I would use that address. If there are different addresses for each home you can pick any one of them to report, or report multiple entries for each location. The Commentary Paragraph 4(a)(9) Comment 4: Property location - mobile or manufactured home. If information about the potential site of a mobile or manufactured home is not available, an institution reports using the Code for "not applicable".

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#2053617 - 12/10/15 07:21 PM Re: Mobile Home loan Catm1991
Catm1991 Offline
100 Club
Joined: Jul 2014
Posts: 194
MO
I used the Dad's address since that is where is he is going to set the MH he purchased until he finds land for himself. Thank you.

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