Other than HMDA reportable and possible flood insurance requirements, are there any other rules (appraisal rules or maximum lending limit rules) that would apply to Mobile Home Park lending? We are looking to finance a commercial loan that is secured solely by the real estate (pads only – NO homes).
Where would it be classified for qualified thrift lender test? “

From what I can see, the QTL is looking at actual manufactured homes, not just sites. I would discuss with your finance area and your exam team. But the rules for residential real property do not appear to cover just the land with pads.

HMDA and the QTL test have different goals.

Manufactured Housing

Manufactured housing is defined by the National Manufactured Home Construction and
Safety Standards Act (42 USC 5402(6)) as:


“A structure, transportable in one or more sections, that in traveling mode measures at least
eight feet by forty feet, or when erected is at least 320 square feet, and that is built on a
permanent chassis and designed to be used as a dwelling with or without a permanent
foundation when connected to the required utilities, and includes the plumbing, heating,
air-conditioning, and electrical systems contained therein.”


Residential Housing

For QTL purposes, as defined in 12 CFR 141, residential housing includes residential real
estate and dwelling units. Section 141.23 defines residential real estate (or residential real
property):
• Homes (including condominiums and cooperatives).
• Combinations of homes and business property.
• Other real estate used primarily for residential purposes other than a home (but which
may include homes).
• Combinations of such real estate and business property involving only minor business
use.
• Farm residences and combinations of farm residences and commercial farm real estate.
• Property to be improved by the construction of such structures.
• Leasehold interests in the above real estate.
Section 141.10 defines dwelling unit as: “The unified combination of rooms designed for
residential use by one family, other than a single-family dwelling.”

And lastly: this is a possibility:

For purposes of clause (v), loans made to finance the acquisition or development of
land shall be deemed to be loans secured by an interest in residential real property if, under
regulations prescribed by the Secretary, there is reasonable assurance that the property will
become residential real property within a period of three years from the date of acquisition of
such land; but this sentence shall not apply for any taxable year unless, within such three year period, such land becomes residential real property.