Since Mobile Home only loans (no land as collateral) are no longer applicable under TRID, do we report NA as the rate spread? I came to this conclusion because the guide says, loans not subject to Reg Z would report rate spread as NA.

Applicability to Reg. Z generally, not TRID specifically, is what decides whether a loan's numeric rate spread is reported. So if your mobile home only loan is for consumer purpose and not otherwise exempt from Reg. Z, you'd report the rate spread.

Nothing has changed all that much for mobile home only loans; they never were covered by RESPA; they aren't covered by TRID. But they were and are covered by Reg. Z, if for consumer purpose.

Thanks, raitchjay... we don't have many mobile home only loans - those exceptions to policy always make me take pause.

We have a mobile home loan that is only secured by the mobile home. We are getting an edit that the rate spread is showing it as a HOEPA loan. Because this was done as a consumer loan and not a mortgage, the HOEPA test was not done. Do we go ahead and report on HMDA as a HOEPA loan?

I would imagine you have a lot more issues with this oversight than what goes on your HMDA LAR, but if it's a HOEPA loan, then yes, that's how you report it.

Obi, as RRJ stated you have some issues you need to clear up if you have more of these loans because if the mobile homes are the consumer's primary residence they are most certainly subject to 1026.32.

(a) Coverage. (1) The requirements of this section apply to a high-cost mortgage, which is any consumer credit transaction that is secured by the consumer's principal dwelling, other than as provided in paragraph (a)(2) of this section, and in which:

1026.2

(19) Dwelling means a residential structure that contains one to four units, whether or not that structure is attached to real property. The term includes an individual condominium unit, cooperative unit, mobile home, and trailer, if it is used as a residence.