Does the requirement to send a notice to borrowers who are 45+ days delinquent on a residential mortgage loan under the Homeownership Counseling Act (HOCA) apply to dwelling secured loans that are not otherwise secured by real estate, such as boats and RVs serving as the borrower's primary residence.

The term “residential property” means a 1-family residence, including a 1-family unit in a condominium project, a membership interest and occupancy agreement in a cooperative housing project, and a manufactured home and the lot on which the home is situated.

Would you agree then that boats and RVs would be included as these can be considered a "1-family residence?"

It has to involve land.