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#2148995 - 10/06/17 01:59 PM Mobile Home Park - CRA and HMDA reportable?
Likes to Comply Offline
Diamond Poster
Joined: Nov 2008
Posts: 1,055
In the mountains
Will mobile home parks and assisted-living facilities be reportable for HMDA and also CRA in 2018?
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#2149037 - 10/06/17 03:55 PM Re: Mobile Home Park - CRA and HMDA reportable? Likes to Comply
Banker K, CRCM Offline
Gold Star
Joined: Jan 2010
Posts: 290
Yes for HMDA, see 1003.2(f) Dwelling.

OI-2 Multifamily Residential Structures and Communities.
A dwelling also includes...a manufactured home community. A loan related to a manufactured home community is secured by a dwelling for purposes of [HMDA]...even if it is not secured by an individual manufactured homes, buy only by the land that constitutes the manufactured home community including sites for manufactured homes.

OI-5 Properties with Service and Medical Components.
A property used for both long-term housing and to provide related services, such as assisted living for senior citizens or supportive housing for persons with disabilities, IS A DWELLING and does not have a non-residential purpose merely because the property is used for both housing and to provide services.

However keep in mind transitory residences are excluded still. There are more explanations in those Official Interpretations of that section.
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All comments are mine & should not be taken as legal advice.

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