We have one loan granted to a borrower for the purchase of a 114 pad mobile home park, with is considered a multi-family community. Included with this purchase were 2 park owned mobile homes.

Here's where I'm stuck. Do I report 114, or 116 as the number of units. income from lot rent for 114 pads was used, but monthly rent from the 2 mobile homes was also used. My inclination is 114.

Also, if I'm reading the instructions correctly, for the line item "Manufactured Home Secured Property Type" I am going to enter "3" for not applicable as with 114 pads, the park is considered a multi-family dwelling - regardless of the inclusion of 2 mobile homes owned by the park. The "Manufactured Home Land Property Interest" would also be Not Applicable.

Is this the correct thinking?

Thanks.

Just my thoughts, but if you have a security interest in the 2 mobile homes, then you should report 116. As appears you already know, we are supposed to consider each pad as a unit, so you have 116 units securing the loan. I agree with the second part that you report MH Prop. Type and Land Property Interest (and Income and DTI) are reported as NA for multi-family dwellings.

Thank you, Carolina.

I did end up reporting 116 units as we included income in the underwriting from 116 sources: potential rental from 114 sites PLUS rental from the 2 physical mobile homes also taken as collateral.

I did end up reporting 116 units as we included income in the underwriting

The income used in the underwriting would have no bearing on determining the number of units to report.

The loan is secured by 114 pads in a manufactured home community and 2 park owned dwellings. The loan is secured by 116 units regardless of the income used in the underwriting.

I went by 1003.4(a)(31) commentary:

For the red commentary, I used the 114 pads contained within the MHP.

For the blue commentary, I presumed this would relate to the 2 mobile homes contained on two of the pads, as we do consider the income from those unites in our underwriting.

Is this not, then, the correct interpretation?

Manufactured home community. For an application or covered loan secured by a manufactured home community, the financial institution should include in the number of individual dwelling units the total number of manufactured home sites that secure the loan and are available for occupancy, regardless of whether the sites are currently occupied or have manufactured homes currently attached. A financial institution may include in the number of individual dwelling units other units such as recreational vehicle pads, manager apartments, rental apartments, site-built homes or other rentable space that are ancillary to the operation of the secured property if it considers such units under its underwriting guidelines or the guidelines of an investor, or if it tracks the number of such units for its own internal purposes. For a loan secured by a single manufactured home that is or will be located in a manufactured home community, the financial institution should report one individual dwelling unit.

You would consider the number units to be taken as collateral under your underwriting guidelines. IOWs if you only secure the loan with 75 of the 114 units then you would report 75.

Maybe this will help. - You secure the loan with the 114 pads plus the 2 park owned homes. You base the repayment of the loan on the borrower's income generated from sources other than the pads and the 2 park owned homes. In that case the loan is still secured by 116 units under your underwriting but no income form those units were used. Would you report 0 units not securing the loan or would you report the 116 units securing the loan?

Good point, Dan. Thank you for taking the time to explain.

Bringing this up again. This is the first (and hopefully the last) time we have ever seen this type of loan request. The loan request is to purchase a mobile home park (community) in a popular fishing area with 20 lots. My understanding is as follows:
This is a multi-family dwelling for HMDA with 20 units. Pursuant to the commentary to 1003.4(a)(29), we would report Manufactured Home Secured Property Type as Code 3 - Not Applicable. The Commentary to 1003.4(a)(30), directs us to report Code 5 - Not Applicable for Manufactured Home Land Property Interest. I do not see any special guidance regarding 1003.4(2)(32) so believe this would be reported as 0-20 (depending on if any of the lots were eligible for affordable housing assistance). Is that correct?

Next question, the borrower is considering purchasing the mobile home park (community) 20 lots and also 20 mobile homes already there. The community is still a multi-family dwelling with 20 units. We would also have 20 individual dwellings. I think, based on the commentary to 1003.4(a)(9), we would choose one "address" and report the Mfg Secured Property Type and Home Land Property Interest, based on it. So, if we choose the community, we go with N/A. If we choose one of the individual mobile homes, we report Secured Property Type as Code 1 - Manufactured Home and Land and Land Property Interest as Code 1 - Direct Ownership. Sound correct?

While the mobile homes are great and are not used as transitory fishing "cabins," they are all newer than 6/15/76 and meet the definition of a mobile/manufactured home.

Thank you for you help!

Thanks for laying out your research as the basis for your analysis.


If the loan ends up being secured by the individual manufactured homes as well as the manufactured home community then your loan is secured by manufactured homes and you would report the information accordingly.

1003.4(a)(9) gives you the option to just report one address in the case where multiple dwellings are securing the loan instead of having to report each individual dwelling. 1003.4(a)(5) states to report the construction method for the property identified by (a)(9). However I guess I'm a bit confused. If you have both the pad and MH securing the loan and you report 123 Lake Front Pad 5 aren't you reporting the address for both properties securing the loan? How do you determine if you are reporting the community address or the MH address?

Dan -

Good point. The parcel address would be what I consider the address for the community so, 123 Walleye Way. Each mobile home has an address...123 Walleye Way Lot 5. The mobile homes are titled in the state and the community is assessed and taxed as real property. The mortgage is on the community and then each individual unit will have a security interest perfected via a lien on the title. Thank you for asking!