If we have a manufactured home where the HUD plate has been clearly removed, is it still considered a manufactured home for HMDA purposes in 2018?

I believe so. Just because it doesn't still have the HUD plate attached doesn't mean it's not a manufactured home. It just means someone removed it. Here's some citations to help:

A manufactured home will generally bear a data plate affixed in a permanent manner near the main electrical panel or other readily accessible and visible location noting its compliance with the Federal Manufactured Home Construction and Safety Standards in force at the time of manufacture and providing other information about its manufacture pursuant to 24 CFR 3280.5. A manufactured home will generally also bear a HUD Certification Label pursuant to 24 CFR 3280.11. [Commentary to §1003.2(l) #2]
I bolded the "generally" wording because it shows that the home won't always have this but is still a manufactured home.

Modular or other factory-built homes that do not meet the HUD code standards are not manufactured homes... [Commentary to §1003.2(l) #1]

This shows that the key factor is that the home meets the HUD code standards. Not that it has a data plate.

I imagine, particularly on older homes, this is going to be a common event. If it was originally titled, and it was manufactured post 1976, I would not worry about the plate. Honestly, I can't imagine too many FI's or appraisers actually looking for it.

Agreed. The plate was the new HUD standard in 1976 (I believe), meaning that everything built before that time did not meet the standard. Just because the plate was removed doesn't mean it's no longer a manufactured home. Now, if it was built before 1976, it would clearly not meet the definition of a manufactured home.

If anyone wonders why I specifically mentioned 'titled' above, it's because you cannot always tell the difference between modular/prefab and manufactured. Some are 100 % identical to look at. The difference is manufactured are always titled originally...prefabs are never titled into the first purchaser's name. Even if they originally have a title for the dealer's moving purposes, it won't ever transfer to the first owner.

At least that's what manufacturer's have told me when dealing with manu vs modular and it makes perfect sense.

I was told in a training last week that if it did not have a HUD plate on it any more that it was not considered a HMDA reportable transaction as it was not considered a dwelling. So now I am really confused! And our appraisers do make notations on the HUD plates.

I have trouble believing that. Too many of those plates are removed [or covered up] over time to rely on it actually being there. I am going by date/VINS, etc.

I agree. The HUD plate is a way to determine that it meets the definition of manufactured home, but it's not a requirement.

OK, I have found out there is more to the current situation. Dwelling was originally a double wide, however we do not have any title information, etc. Massive improvements were done on it in 2009 inside and out. The only way you can tell that it was originally a manufactured home is that the appraisal pictures show the metal frame underneath the one section. But a permanent foundation addition has been added and the whole property was pitched under a new roof that totally covers the doublewide. My question now is.... do I still report it as a manufactured home, or do I list it as a 1-4. There is no title information/security agreements. Homeowners insurance does list it as a manufactured home. Thanks for you help!

This is how I would go about it. IF it is no longer chattel [titled], then I might consider it a prefab/modular [which often DO come on chassis] and move on.

How do county records reflect the dwelling? If in doubt, I always defer to the official classification by the governing entity. In our state, this manuf home would probably had title eliminated, marrying the manuf home to the land. The classification would still be a manufactured home, and I would report it as such for HMDA purposes.