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#2153004 - 11/10/17 03:46 PM Manufactured Home Community Loan
Kompliance Offline
Junior Member
Joined: Aug 2012
Posts: 44
Pennsylvania
On page 27 of the CFPB's HMDA Small Entity Compliance Guide for 2018 data collection rules, it states:
"A loan related to a Manufactured Home community is secured by a Dwelling even if it is not secured by any individual manufactured homes, but is secured only by the land that constitutes the manufactured home community."

So, this would be the only time in all of HMDA World where we would report a "land only" loan coming in 2018. My question is, when we have a loan like this we have to report, what are we to report for all the fields that are in relation to the building securing the loan? Such as:

Construction Method
Occupancy Type
Manufactured Home Secured Property Type
Manufactured Home Land Property Interest
Total Units
Multifamily Affordable Units

Do you think we report "NA" for all of these, because there are no buildings securing this loan, just the land? Of course, the CFPB gave us that random blurb, and then omitted any further clarification.

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#2153031 - 11/10/17 04:27 PM Re: Manufactured Home Community Loan Kompliance
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,638
The Swamp
My thoughts would be [under most circumstances]

2-Manufactured Home
3-Investment
1-manufactured home and land
Will depend on situation, but I'd bet most often would be 1-Direct
Units - # of pads [not including RV pads]
Will depend if there are any
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#2153073 - 11/10/17 06:37 PM Re: Manufactured Home Community Loan Kompliance
Kompliance Offline
Junior Member
Joined: Aug 2012
Posts: 44
Pennsylvania
I keep going back and forth between these answers which would be referring to the mobile homes that will be parked in the community (but are not actually part of the collateral) and just reporting "NA" for these because really, there is no actual "dwelling" tied to the loan. However, I struggle with using "NA" as well because this exemption isn't listed as a reason for any of these fields in the CFPB's "Reporting NA" chart. However, for the "Construction Method" field, you don't have an NA option, so I guess you would be required to put a "2- Manufactured Home" because that is the only logical answer (although sometimes I fell like trying to apply logic when determining HMDA reportablility is dangerous smile ). So, we could follow that same logic for the other fields as well and use what RRJoker suggested above. I just wish that they would have given us additional guidance on this if they were going to add it to the list of reportable transactions because we do quite a few of these Manufactured Home Community loans.

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#2153089 - 11/10/17 07:18 PM Re: Manufactured Home Community Loan Kompliance
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,638
The Swamp
consider this. A manufactured home community is considered a 'dwelling' for HMDA [illogical] purpose wink
_________________________
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Say you'll haunt me - Stone Sour

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#2153105 - 11/10/17 08:03 PM Re: Manufactured Home Community Loan Kompliance
raitchjay Offline
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Joined: Oct 2009
Posts: 8,450
OK
The next manufactured home community loan we make will be our first, so i have nothing to offer...but i'm bookmarking this thread just in case. smile
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#2153106 - 11/10/17 08:09 PM Re: Manufactured Home Community Loan Kompliance
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,638
The Swamp
We have at least one on the books laugh! We made sure to renew it this year smirk
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#2153117 - 11/10/17 08:18 PM Re: Manufactured Home Community Loan Kompliance
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,450
OK
LOL.....nice move.
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