One of our lenders is making a loan to make improvements to mobile homes in a mobile home park. He is not taking titles to the mobile homes, nor referencing any particular mobile home specifically. He is only taking a mortgage on the legal description of the land. It seems that the mobile homes are part of the assets of the business and they are merely rented out to the tenants. We do not formally classify any loan as a home improvement loan.
I'm leaning towards not HMDA reportable, but I am easily swayed! Any thoughts?