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#2232422 - 03/05/20 05:05 PM Mobile Home Only
Nicole Offline
100 Club
Joined: Nov 2018
Posts: 158
Hello, it's been a while since i have seen a loan secured by a mobile home only title and is primary residence. What applies here, do we do TRID? LE/CD?

Thank you!

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Lending Compliance
#2232424 - 03/05/20 05:12 PM Re: Mobile Home Only Nicole
Gertie Offline
Member
Joined: Jan 2016
Posts: 83
Start with Reg B Appraisal Rules. https://www.bankersonline.com/regulations/12-1002-014
Also if Consumer purpose, take a look at Reg Z for Ability to Repay.https://www.bankersonline.com/regulations/12-1026-043

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#2232425 - 03/05/20 05:13 PM Re: Mobile Home Only Nicole
Gertie Offline
Member
Joined: Jan 2016
Posts: 83
If there's no dirt, then TRID will not apply.

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#2232429 - 03/05/20 05:20 PM Re: Mobile Home Only Nicole
Nicole Offline
100 Club
Joined: Nov 2018
Posts: 158
So besides Ability to Repay and Reg B do we have any preliminary disclosures?

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#2232431 - 03/05/20 05:22 PM Re: Mobile Home Only Nicole
Gertie Offline
Member
Joined: Jan 2016
Posts: 83
If it is closed end, that should cover it. .

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#2232434 - 03/05/20 05:23 PM Re: Mobile Home Only Nicole
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 566
Petersburg, VA
I believe a RESPA GFE would be required.

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#2232442 - 03/05/20 05:43 PM Re: Mobile Home Only Nicole
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,105
OK
RESPA won't apply if there's no dirt securing the loan.
_________________________
I'm fixin' to fix that.

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#2232443 - 03/05/20 05:43 PM Re: Mobile Home Only Nicole
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
No dirt - no RESPA either
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2232447 - 03/05/20 06:01 PM Re: Mobile Home Only Nicole
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 566
Petersburg, VA
Ah thanks, I don't know why I was thinking the loan was considered a federally related mortgage loan under RESPA.

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