Thread Options
#2254166 - 05/20/21 04:36 PM HMDA OR NOT??
MSB05MS Offline
Member
Joined: Jan 2008
Posts: 92
I am reviewing an adverse action and I am in question if HMDA reportable or not.The consumer application purpose and proceeds were for "other" consumer purpose for debt consolidation. The borrower stated he would pledge a mobile home as collateral. The loan interviewer did not get the physical address of the mobile home nor year, make and model of the mobile home. The application only has residential dwelling, mobile home, consumer use checked, not homestead property. No real estate was to be pledged as collateral.
Do we have a HMDA application?

Return to Top
HMDA

   
HMDA Academy
#2254167 - 05/20/21 04:43 PM Re: HMDA OR NOT?? MSB05MS
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
You don't have to have 'dirt' to have a HMDA reportable application like you do with TRID. Your potential loan request would require a security interest in a dwelling, and a mobile home (unless manufactured prior to June 15, 1976) is a dwelling.

From your description this appears, to me, to be HMDA reportable as 'other'.
_________________________
My Opinions Only

Return to Top
#2254168 - 05/20/21 04:43 PM Re: HMDA OR NOT?? MSB05MS
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,668
OK
Yes.
_________________________
I'm fixin' to fix that.

Return to Top
#2254169 - 05/20/21 05:15 PM Re: HMDA OR NOT?? MSB05MS
MSB05MS Offline
Member
Joined: Jan 2008
Posts: 92
I have no information to document the year model of the mobile home, so I do not know if it was manufacture prior to June 15, 1976.

Return to Top
#2254170 - 05/20/21 05:23 PM Re: HMDA OR NOT?? MSB05MS
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
While I totally understand that, it doesn't lessen your responsibilities as far as HMDA is concerned. I also see some training opportunities in your future.
_________________________
My Opinions Only

Return to Top
#2254173 - 05/20/21 05:39 PM Re: HMDA OR NOT?? MSB05MS
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,668
OK
I agree with Skittles and would add......if you can't verify when the MH was manufactured, i think you have to default to the idea that it was NOT manufactured prior to June 15, 1976, especially since that would most definitely be outside the norm for today.
_________________________
I'm fixin' to fix that.

Return to Top

Moderator:  SMQ, CRCM