We have loans to an employer to reimburse them for the purchase of mobile homes to house workers. Each loan is secured by a mobile home. While I know these are transitory circumstances that won’t be reported on the HMDA LAR, what Call Report code would be most appropriate? 1c2a (1-4 family – secured) or 1e2 (non-OOCRE)? I am trying to confirm whether or not there is a case for them to be reported on the CRA LR itself (not just considered separately). Thanks for the feedback…

Please note that the bank has a loan to the same borrower secured by the land on which these mobile homes are located. Because the mobile homes are fastened to land that the same borrower owns, they are considered real property in Texas (not personal property). However, with the subject loans only being secured by the manufactured homes and not the land (although we have a separate loan for the land), would we report these with a Call Report Code of 4a, or should it be 1e?

"Because the mobile homes are fastened to land that the same borrower owns, they are considered real property in Texas (not personal property)."

That has nothing to do with whether a mobile home is personal property or part of the real property in the State of Texas. They would have to have filed a Statement of Location for each home for them to be considered real property. If they are part of the real property, it would be impossible to take a lien only on the mobile homes.