Wanted to verify that this is correct. Customer is purchasing a RV as their primary residence.
- HPML rules apply (escrow)
- HMDA exempt
- Loan Estimate/Closing Disclosure exempt
- HOEPA applies

-HPML rules apply (escrow) = NO
1026.2(a)(19) Dwelling
2. Use as a residence. Recreational vehicles, campers, and the like not used as residences are not dwellings.

- HMDA exempt = Correct

- Loan Estimate/Closing Disclosure exempt = Correct (No DIRT)

- HOEPA applies = Correct
Mortgages secured by manufactured housing (whether titled as real property or personal property) and other types of personal property (e.g., an RV or a houseboat) are subject to HOEPA coverage if the dwelling is the consumer’s primary residence.

1026.2(a)(19) Dwelling
2. Use as a residence. Recreational vehicles, campers, and the like not used as residences are not dwellings.

I read the same section and thought that escrow did apply because they are using the RV as a residences. Since it will be their primary escrow will apply.

The RV fits the definition of dwelling in this case. If it is to be the borrower's principal dwelling, and the APR over APOR spread exceeds one of the three thresholds in 1026.35(a)(1), it will be an HPML, and will be subject to the HPML escrow requirements unless you, as the lender, are exempt from those requirements. You'd have to escrow for insurance and any periodic taxes imposed on the RV (personal property taxes included).

Otherwise, I agree with Ski's analysis.

Thanks John. That was the one I thought might be Yes, but the definition threw me off.

Thanks for the clarification.