Loan secured by a vehicle to start construction of foundation in which the borrower will eventually affix a mobile home that they already own. Would this be a home improvement loan? My thoughts is that it would not be a construction loan because the mobile home is already constructed, however the foundation is going on bare land and it really wouldn't be a dwelling. It will improve the dwelling when the mobile home is place on top of it.
I am leaning towards not HMDA reportable due to it being non-dwelling secured and it isn't improving a dwelling directly. But if anyone else has an opinion, I would love to hear it

its not HMDA unless you "classify" these types of loans as home improvement loans. (which we don't and I don't know of many that do)....

In my opinion you have a personal loan secured by an auto.

Others may disagree. Good luck!

must be a really nice vehicle

LOL right!!

We do classify our Home Improvement loans. My issue is, if this is a home improvement loan, we would then report on the property being improved, so it would be the bare land. Or would it be the mobile home, and if that were the case, what address would I use.

bump

Yikes... that is a tough call. I would probably reach out to a guru...

I think it could be argued either way.

HMDA reportable - report the address the foundation is being built on which will eventually house the mobile

OR

HMDA Exclude - Cash out to improve bare land that does not currently have a dwelling.

I'm honestly not sure which way I would lean. Probably towards HMDA exclude. Sorry I'm not of much help - hopefully an expert will opine.

I appreciate your answer, I am right there with you. Could be one of those just pick on and document scenarios.

I wouldn't report it; there is currently no dwelling on the land, so i don't see how it would meet the criteria of "or improving the real property on which the dwelling sits". JMO.

Thank you Raitchjay, I appreciate your opinion in this matter.

This is a doozy. I'll take a stab at it.

I don't see this as a home improvement loan. Home improvement is repairing, improvement, etc. to an EXISTING DWELLING or the real property on WHICH IT IS located.

I could see this as a construction loan (which could be a purchase) if it's not temporary. However, you say "the borrower will eventually affix a mobile home". So it sounds like this loan is not used to construct yet. Like you say in your first post, it will be a dwelling WHEN the mobile home is placed on it. If you do that loan, I'd call that the construction/purchase for HMDA.

Therefore, I don't think you have a HMDA reportable transaction with this loan.

They already own the mobile home, so I don't see it as a purchase, regardless. I'm with raitchjay's logic on this one. No house, no HMDA.

Thank you both for your feedback. Taking into account your responses, I am going with my gut also on this one and not reporting it.