We have a request from a customer to take the equity out of his recreational travel trailer. The trailer is sitting on his land and is where he lives. Would this be considered a dwelling and subject to TRID?

It does not really matter if you are taking the land as collateral, because that is the key - consumer purpose plus real property equals TRID. What sits on the property is neither here nor there.

If they are using the travel trailer as a residence however, it would be a dwelling.

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.

rlcarey,

Thank you for the response. Got it. No TRID however, the right to rescind would apply. Thanks again.