We have a borrower looking to purchase a single wide 3 bd / 2 ba mobile home and locate it on property.
There is a mobile home already on the property that will be removed and trailer will be placed in it's stead. The home has actually already been removed.

Borrower is also 1/3 owner of ABC Farms. Due to the location of the mobile home
ABC Farms will have to pledge the land as collateral. The entity does
not take on any financial liability, however..

$111,500.00 Mobile Home purchase
$10,000.00 Crane fees / removal & placement of new trailer
$10,000.00 Misc expense / Septic installation
$131,500.00 Finance Amount

Where borrower plans to place the mobile home already has a foundation and a stable driveway
where the crane can be placed to remove/install the mobile homes. Septic and well are
both possible. To get electricity to the mobile home there is one plug to power the entire
home.

I am thinking for both TRID and HMDA this would be considered purchase?

It would be a home equity. You are not purchasing the land identified in paragraph (a)(6)..

1026.37(a)(9)(i) Purchase. If the credit is to finance the acquisition of the property identified in paragraph (a)(6) of this section, the creditor shall disclose that the loan is for a “Purchase.”

I will let someone else comment on HMDA.

Purchase for HMDA. You don't mention any existing loans secured by the subject property, so as stated, it sounds like a Home Equity loan for TRID.

Does it matter that borrower is having the mobile home built offsite? I don't think it would be considered construction but guess I should throw that out there.

If the borrower is purchasing it, whether whole or in pieces, it's a HMDA purchase.

Okay and still home equity for TRID?

yes

Thanks!!!

Due to the location of the mobile home ABC Farms will have to pledge the land as collateral.

If the land the MH will be located on is used primarily for agricultural purposes the loan is not subject to HMDA reporting.

Thank you, I was so focused on the "building/constructing" of the mobile home I didn't even consider that. Well that makes it super easy.

Good catch Dan. Didn't even think to go there.