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#2101188 - 09/30/16 03:13 PM Mobile Home Park
TMatt87 Offline
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TMatt87
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Idaho
We are refinancing a mobile home park. The appraisal notes that the spaces are rented at below market value. Could this be counted as a community development loan for affordable housing? The park is located in a moderate income location.
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#2101207 - 09/30/16 03:41 PM Re: Mobile Home Park TMatt87
Pale Rider Offline
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Ideas of how an examiner will look at this gets quite esoteric when comparing rents and what is below market. I doubt they will take an appraiser's word for it, although they may be considered a third party to the bank. Any idea what rent the appraiser was using for market rent? When he established the market rent, did he then take 80% of that number to determine the rent for low-and-moderate-income individuals to determine affordability?

But don't give up, since it is an LMI tract, maybe you can argue stabilization rather than affordable housing.
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#2101213 - 09/30/16 03:46 PM Re: Mobile Home Park TMatt87
Kathleen O. Blanchard Offline

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Agree that you will need more info to back up the statement of below market rent.

If there are aspects of the use of funds that could support stabilization/revitalization (fixing up the park?), that is work examining.
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#2108816 - 11/28/16 09:23 PM Re: Mobile Home Park TMatt87
wblewis935 Offline
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I'd like to bring this thread back up, if I may. I'm having a serious case of brain freeze... and not the good Ice Cream kind.

We have a similar situation. However, we reported this as a HMDA loan. So, my question; Mobile home parks aren't considered multifamily, correct? Since each individual mobile home is considered a single-family dwelling.

If that is the case, I wouldn't be able to present this as affordable housing (below market rents) for CD to an examiner, since it is HMDA reported. Am I thinking this through correctly?
Last edited by wblewis935; 11/28/16 09:24 PM.
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#2108863 - 11/29/16 09:58 AM Re: Mobile Home Park TMatt87
Kathleen O. Blanchard Offline

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Under current rules, it depends upon what your collateral is. Are you secured by actual dwellings?

Under revised rules, a mobile home park (manufactured home community) is considered a dwelling for HMDA even if no homes are on the site pads. Each pad is a unit and a park with 5 or more is multifamily.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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