Would you consider when a mobile home is being purchased and installed on land that it is a construction loan? My opinion is that construction is that the dwelling will be constructed from the ground up. Other opinions in our FI is that since we are financing "construction" activities such as infrastructure installed, home delivered and connected to land, utility installation, possible road construction to right-of-ways, foundation installed (grading, footer, foundation, etc.) that it is a construction loan.

Are you treating these as construction loans in you FI?

Would you disclose the purpose on an LE and CD as Construction or Home Equity Loan if the land is not being purchased or refinanced?

How do you report these for HMDA?

It will be a HE for TRID...how you treat it for loan structure will depend on whether you set it up for single advance or multiple..

Thanks for the help.

Regarding HMDA, if the loan structure is initially a drawn down line of credit, interest only for 6 to 12 months and the loan will be refinanced into permanent financing when it matures, would the permanent loan be reported as a purchase for HMDA or a refinancing?

Yes, you only "construct" a home once and from the ground up. The mobile home, unless it is really a modular home to be built "on-site", will be constructed (manufactured) elsewhere and moved to your "prepared site" to be affixed to the foundation.

I think your initial loan is a temporary loan (due to the short term AND the permanent financing to follow) to prepare the land for the arrival of the mobile home. I would not report it for HMDA and agree that it is a Home Equity loan for TRID purposes.

When the permanent financing is performed, I would call it Refinancing for TRID purpose and Purchase for HMDA.

Hope this helps.

FWIW, i agree with Ski.