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#2093680 - 08/17/16 02:24 PM Mobile Home HI
George Offline
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Joined: Apr 2016
Posts: 364
So, I believe this loan is reportable, but just wanted to get opinions/confirmation. Scenario:

Customer purchasing mobile home (financed through company) to be placed on land owned by family. We are providing non-dwelling secured loan to run/install sewage and water. Home improvement, yes?

I don't know why I feel wish-washy on this one!

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#2093704 - 08/17/16 03:09 PM Re: Mobile Home HI George
Rocky P Offline
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Joined: Jun 2003
Posts: 7,650
Florida
Wishy-washy/water and sewer - sure, no pun intended!

If your institution classifies non-secured as HIP, you have a go!
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#2093770 - 08/17/16 05:40 PM Re: Mobile Home HI George
JSD Offline
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JSD
Joined: Oct 2000
Posts: 512
USA
Has the dwelling - mobile hone - been delivered? To be reported as HI a dwelling must be present.

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#2093772 - 08/17/16 05:48 PM Re: Mobile Home HI George
George Offline
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Joined: Apr 2016
Posts: 364
I am not sure if it has, or if the borrower made arrangements to hold delivery until the property was ready.

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#2093806 - 08/17/16 06:58 PM Re: Mobile Home HI George
Ski Offline
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Joined: May 2003
Posts: 639
South Louisiana
JSD, can you point to where in the HMDA GIR it says that the mobile home has to be present to be reported as a purchase?

Home purchase loan.
A home purchase loan is any loan secured by and made for the purpose of purchasing a dwelling. See the definition of “dwelling.”

Dwelling.
Dwelling means any residential structure, whether or not attached to real property. It includes vacation or second homes and rental properties; multifamily as well as one- to-four-family structures; individual condominium and cooperative units; and manufactured homes. It excludes recreational vehicles such as boats and campers, and transitory residences such as hotels, hospitals, and college dormitories.

I don't see anything in the above definitions from the glossary indicating anything like that.

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#2093813 - 08/17/16 07:15 PM Re: Mobile Home HI George
George Offline
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Joined: Apr 2016
Posts: 364
Ski, I believe the difference comes from purchase compared to home improvement. Per Appendix D, if information about the potential site is not available, report NA for property location. I take this to mean that the home does not have to be delivered in order to report as a purchase.

However, I understand JSD's point about a dwelling be present in order to be a home improvement; which is what I am asking about. My only question to that is, if home improvement includes the real property, then why would this still not be an HI reported loan?

To Rocky's point, we do internally classify our non-dwelling secured as HI if they fit.

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#2093821 - 08/17/16 07:54 PM Re: Mobile Home HI George
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,841
The home improvement definition contains ' ...or improving a dwelling or the real property on which a dwelling is located...' If the MH hasn't been delivered yet, your situation likely doesn't meet this part of the definition. Also, if you classify and report unsecured home improvement loans, you need to classify and report all of them. Many institutions don't.

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#2093827 - 08/17/16 08:09 PM Re: Mobile Home HI George
George Offline
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Joined: Apr 2016
Posts: 364
Yes ma'am, unfortunately we do :/, and we do. So, since we do have it classified as such and we want to stay consistent, should I report it even if it doesn't technically meet the definition? Or do we need to be literal with the definition?

This is, of course, all assuming that the mobile is not already delivered. And, since I have no evidence to the contrary, can't I go based off the assumption that it is delivered?

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#2094020 - 08/18/16 04:44 PM Re: Mobile Home HI George
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Have they purchased the home already or will the purchase be essentially simultaneous with your loan? In that case, I could stretch to calling it home improvement because without those improvements they have no home.
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#2094078 - 08/18/16 07:07 PM Re: Mobile Home HI George
George Offline
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Joined: Apr 2016
Posts: 364
It is pretty much simultaneous. I am not 100% sure, but I believe the borrower signed for the mobile home just before signing for our loan. That's kind of why I was leaning towards reporting it too, Kathleen!

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