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#2249880 - 02/28/21 12:22 PM Mobile Home Parks
terpsfan Offline
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Joined: Feb 2007
Posts: 2,059
Given mobile home parks for which we are not taking the homes are still HMDA reportable would these be double reported as the loan would be reported for CRA as a small business loan because it falls under 1E2?

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#2253612 - 05/06/21 08:19 PM Re: Mobile Home Parks terpsfan
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
Assuming 1E2 is the correct place for a Mobile Home park with the lots only as collateral, then this may be an area where the guidance issued on double reporting doesn't account for this type of situation. If the Mobile Home park qualified for CD credit, then it would be pretty clear to me that you could get CRA Community Development consideration and report for HMDA. However, as far as double reporting on the HMDA LAR and the CRA LAR, I do think it would actually apply here (again, if 1E2 is the correct code).

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