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#2261731 - 10/27/21 09:39 PM Mobile Home Park
JobSecurity Offline
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Joined: Oct 2009
Posts: 582
If the bank has a loan that is secured by both a mobile home park and mobile homes, do we follow the HMDA reporting as a mobile home park? This sounds stupid, but I was not able to find or overlooked where it clarified this.

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#2261756 - 10/28/21 03:36 PM Re: Mobile Home Park JobSecurity
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,958
Bloomington, IN
I'm not sure I understand what you are asking. If the loan is secured by the pads within a MH park the loan is secured by a manufactured home community and each pad is a dwelling for HMDA reporting purposes regardless if there is a MH located on the pad.

If the loan is secured by 10 pads and 10 individual mobile homes the loan is secured by 20 total units.

5.18 Total units
For a Covered Loan, a Financial Institution reports the number of individual Dwelling units
related to the property securing the Covered Loan. For an Application, it reports the number of
individual Dwelling units related to the property proposed to secure the Covered Loan.

12 CFR 1003.4(a)(31).
For an Application or Covered Loan secured by a Manufactured Home community, the Financial
Institution should include the total number of Manufactured Home sites that secure the loan
and are available for occupancy, regardless of whether the sites are occupied or have
Manufactured Homes attached. For a loan secured by a single Manufactured Home that is or
will be located in a Manufactured Home community, the Financial Institution should report one
individual Dwelling unit. Comment 4(a)(31)-2.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2261865 - 10/29/21 09:24 PM Re: Mobile Home Park JobSecurity
JobSecurity Offline
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Posts: 582
I was trying to get at if we considered it a MH park and looked at it from that perspective. I have read the 1003.4(a)(31) but when I read that I take it to mean we count the total number of home sites that are available (inhabitable) in your example 10.

It seems we are over reporting if we say 20 and there are only 10 pads available, there will never be 20 units? So if i have 10 pads and 5 mobile homes we report 15? Ugh!

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#2261941 - 11/01/21 09:04 PM Re: Mobile Home Park JobSecurity
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,637
Yes, if you have 5+ units, then you consider it as a "Manufactured Home Community," which is a type of Multifamily Dwelling. I think you may be misunderstanding what Dan was saying in his 20 example, if I am following you correctly. I believe his example was there are 20 pads as a whole, 10 of which have actual Manufactured Homes on them and 10 of which are vacant pads. If you only have 10 total pads, but 5 are occupied, then your total units is 10.

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#2261966 - 11/02/21 02:15 PM Re: Mobile Home Park JobSecurity
JobSecurity Offline
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Joined: Oct 2009
Posts: 582
Thank you CNABW. I am confused about a lot of things regarding HMDA recently. So when I have both a mobile home park and mobile homes as collateral, the bank would take the total number of pads in the mobile home park because it is a multfamily and ignore any mobile homes on those pad in my count? That makes more sense to me now.

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#2261986 - 11/02/21 06:01 PM Re: Mobile Home Park JobSecurity
Rocky P Offline
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Joined: Jun 2003
Posts: 7,441
Florida
Think of it as an apartment building that has 10 units. 5 of the units are occupied, but for HMDA, it's reported as 10 units, the total available - occupancy is irrelevant.
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#2261994 - 11/02/21 06:32 PM Re: Mobile Home Park JobSecurity
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,958
Bloomington, IN
Each pad within a MH Community is considered a dwelling unit regardless if there is an individual MH located on it. Therefore if the loan is secured by those 10 pads the loan is secured by 10 units.

Each MH is considered a dwelling unit. If the loan is additionally secured by 10 individual MHs the loan is secured by 10 additional units.

10 pads plus 10 MHs makes the loan secured by 20 units.

If the property had 2 individual site-built dwellings located on it would you only report 1 unit because they are on the same property? No, you would report 2 individual units; and by definition the pad and the MH are each individual units.

(f) Dwelling means a residential structure, whether or not attached to real property. The term includes but is not limited to a detached home, an individual condominium or cooperative unit, a manufactured home or other factory-built home, or a multifamily residential structure or community.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2262091 - 11/04/21 12:34 PM Re: Mobile Home Park JobSecurity
JobSecurity Offline
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Joined: Oct 2009
Posts: 582
Thank you Dan. I hope this is the last mobile home park.

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#2265552 - 02/01/22 02:52 PM Re: Mobile Home Park JobSecurity
complyorelse Offline
Gold Star
Joined: Nov 2007
Posts: 442
U.S.
We have an application that seems to fall into the manufactured home community definition but there are some components that are causing me to be confused. Here are the particulars:

0ne parcel owned by two individuals who are also the borrowers. The owners live in a SFR on the property; it is their primary residence. There are 8 manufactured homes with long term leases although several of them are very old (pre 1976). The property appraiser is the only information I have to rely on because there is no appraisal and they use "manufactured/mobile home" for the descriptions but do give me the year built. There are also 3 cottages which I can only assume are site built, and 2 RV pads.

I'm struggling with how we should handle the units that are pre 1976 - should they be included in the count at all?

If we report as site built because of the SFR and cottages, how does that affect the entire manufactured home community piece? Does it still qualify as a manufactured home community?

I am also ultra confused on the count of the manufactured home sites because this thread seems to have conflicting interpretations. There are 8 manufactured homes and there are no empty pads. So, assuming all would be included in the count, is it 8 or 16? 8 makes sense to me but I am confused by Dan's response.

Do the RV pads count? I know RVs are excluded but we "may" include RV pads in the count.

Lot's of questions!! I appreciate any help.

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#2265588 - 02/01/22 06:16 PM Re: Mobile Home Park JobSecurity
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,958
Bloomington, IN
I'm struggling with how we should handle the units that are pre 1976 - should they be included in the count at all?

If they are pre 1976 then for HMDA purposes they are not dwellings.

If we report as site built because of the SFR and cottages, how does that affect the entire manufactured home community piece? Does it still qualify as a manufactured home community?

When multiple dwellings are involved you pick one and report the applicable information for that property. You are still however secured by a manufactured home community.

There are 8 manufactured homes and there are no empty pads. So, assuming all would be included in the count, is it 8 or 16?

This answer will depend how many of the pre 1976 MHs are located on the pads and if they secure the loan. For HMDA purposes each MH pad securing the loan is a dwelling and each MH (post 1976) securing the loan is a dwelling.

Do the RV pads count? I know RVs are excluded but we "may" include RV pads in the count

Official Interpretation
Paragraph 4(a)(31)
1. Multiple properties. See comment 4(a)(9)-2 regarding transactions involving multiple properties with more than one property taken as security.

2. Manufactured home community. .. . . . . A financial institution may include in the number of individual dwelling units other units such as recreational vehicle pads . . . . .
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2265597 - 02/01/22 07:16 PM Re: Mobile Home Park JobSecurity
complyorelse Offline
Gold Star
Joined: Nov 2007
Posts: 442
U.S.
Dan, I really appreciate your feedback!

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#2270205 - 05/09/22 06:59 PM Re: Mobile Home Park JobSecurity
Help! Compliance Offline
Member
Joined: Oct 2012
Posts: 93
San Antonio, TX
1) So with mobile home communities/parks having similar considerations as a multi-family property, would there call code be the same (1d), instead of 1c2?

2) If only land, pads, and utilities serve as collateral (no actual manufactured/mobile homes or community structures), would the call code be the same as a loan secured by a lot (1a2), or because of the pads themselves being considered as dwellings, would it be coded as prescribed in my #1 (1d or 1c2)?

3) If pads are involved, would the fact that the homes that sit on them were built prior to 1976 be a moot point as the pads themselves are counted as dwelling units?

While I am aware that call codes aren't directly related to HMDA, establishing what they should be does solidify if and how the application should be reported on the HMDA LAR. For example, lot loans have never been reported on the HMDA LAR, and multi-family properties are coded as 1d.

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