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#2169777 - 03/23/18 12:15 PM Periodic Statements - No land MH not Own Occ
Compliance NABW Offline
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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)?

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#2169781 - 03/23/18 12:37 PM Re: Periodic Statements - No land MH not Own Occ Compliance NABW
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 78,649
Galveston, TX
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.
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#2169844 - 03/23/18 03:15 PM Re: Periodic Statements - No land MH not Own Occ Compliance NABW
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Thank you for confirming that. I guess it would be more of a hassle for a servicer to have to make that distinction though.

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#2171229 - 03/31/18 02:10 PM Re: Periodic Statements - No land MH not Own Occ Compliance NABW
Ms. X Offline
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Joined: Jan 2018
Posts: 24
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!

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#2171233 - 04/01/18 11:45 AM Re: Periodic Statements - No land MH not Own Occ Compliance NABW
rlcarey Online
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rlcarey
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Galveston, TX
Both are correct statements.
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#2171261 - 04/02/18 01:37 PM Re: Periodic Statements - No land MH not Own Occ Compliance NABW
Ms. X Offline
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Joined: Jan 2018
Posts: 24
Thanks!

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#2171275 - 04/02/18 02:12 PM Re: Periodic Statements - No land MH not Own Occ rlcarey
John Burnett Offline
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John Burnett
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Cape Cod
Originally Posted By rlcarey
Both are correct statements.
...unless your institution qualifies as a small servicer under ยง1026.41(e)(4), in which case it isn't required to comply with any part that section.
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