I was doing a lot of reading in Reg. Z related to the requirements to provide the periodic statement for mortgage loans. I was wondering others' take on providing a periodic statement for a loan secured by a mobile home with no land where the structure was not used as the primary residence of the borrower. There is some language in Reg. Z that makes it seem like a periodic statement would be required in this situation because the mobile home is still a "dwelling." However, I also began to consider that there might be a difference based on the loan size. In other words, as it is not secured by real property and is not used as the primary residence of the borrower, would it actually be exempt from Reg. Z if the loan amount exceeded the $54,600 threshold (or whatever the current number is)?

The threshold exemption does not apply to a loan: Secured by any real property, or by personal property used or expected to be used as the principal dwelling of the consumer.

So, if MH is not a principal dwelling and over the current exemption amount of $55,800 or the applicable amount when the loan was granted, it would not be covered under Regulation Z.

Thank you for confirming that. I guess it would be more of a hassle for a servicer to have to make that distinction though.

Just in need of confirmation - A no land mobile home used as primary dwelling is subject to periodic statements (including loans in bankruptcy) with no dollar threshold - true? Same for mobile home with land no matter if principal dwelling or not?
Thanks!

Both are correct statements.

Thanks!

...unless your institution qualifies as a small servicer under §1026.41(e)(4), in which case it isn't required to comply with any part that section.