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#2238812 - 06/30/20 01:43 PM Camper as Primary Residence
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
We have had a request or inquiry about a loan where the customer will permanently park a camper at a campground and the camper will be their primary residence. This shouldn't be TRID since there isn't any "dirt" being taken but what all would be triggered for it being primary residence? Would we be required to issue a TIL statement?

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Lending Compliance
#2238814 - 06/30/20 01:50 PM Re: Camper as Primary Residence mdog76
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 78,584
Galveston, TX
TIL? - Consumer purpose - used as a residence - of course.

Official Interpretation

2(a)(19) Dwelling

2. Use as a residence. Mobile homes, boats, and trailers are dwellings if they are in fact used as residences, just as are condominium and cooperative units. Recreational vehicles, campers, and the like not used as residences are not dwellings.
The opinions expressed here should not be construed to be those of my employer:

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#2238856 - 06/30/20 08:37 PM Re: Camper as Primary Residence mdog76
RebekahL CRCM Offline
Platinum Poster
RebekahL CRCM
Joined: Feb 2003
Posts: 786
Big Sky Country
Like Randy said, you'll certainly have to issue TIL disclosures by mere fact that it is a consumer loan.

If the loan is for more than 12 months, then taking their principal dwelling (regardless that it is a recreational vehicle) will also trigger ATR / QM underwriting (1026.43) requirements. Further, I imagine the pricing of such a loan will be surely higher than a stick-built home, likely triggering it as an HPML (1026.35). If so, you'll need to escrow for personal property taxes and insurance (even though there is no real estate). It could even end up being a HCML (1026.32) too, subject to numerous rules.
Me, Type A? Maybe - I'm not done analyzing it yet.

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