Here's an odd one. Purchase of MH's, secured by the MH's being purchased, no dirt, borrower is a used MH dealer.

According to HMDA, this is a reportable purchase of manufactured housing, not owner occupied, UNLESS it will meet the temporary financing exemption. Our primary repayment source is sale of the MH's in question - but in light of the recent "temporary financing" debaucle - I'm a bit stumped as to what to do with this.

Intent would put them as CRA reportable small business loans, but the letter of the reg seems to imply that they should be HMDA?

Sounds like a flooring line for the mobile home dealer - IMHO - you can't get more temporary than that.............. If these are not temporary loans - you have real problems....

They are short-term single pays, but the particular loan in question has become a bit evergreen. It's not a Line of Credit or I wouldn't question it at all. The borrower appears to buy 3 or 4 MH's at a time, finance them all together on a single pay note, and then rotate the collateral as necessary upon renewal.

It's a bit of a mess, and I fully intend to demand explanation from the LO as to WHY exactly this is set up this way....but in the meantime I'm stumped as to how to report. It is showing up on my loan system query under "MH purchase and refi."

Argh!

Sounds like you do have a structuring problem from a loan operations standpoint, but I don't think that fact changes the fact that this is the equivalent of a flooring line. IMHO- I wouldn't be reporting these.

OK, thanks. Sometimes I get a bit too tangled up in the trees to see the whole forest.

The following is from the 2003 GIR, for some reason the same wording did not carry over to the 2004 GIR, however I'm in total agreement with Randy that these are not reportable.

Loans that, although secured by residential real estate, are made for purposes other than home purchase or home improvement, or refinancing (for example, loans to finance tuition, a vacation, or goods for business inventory)

Someone told me that these MHs are inventory, not homes; report as CRA not HMDA. Now that made sense, sure hope they were right.