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#1023809 - 08/20/08 02:03 PM Manufactured Home loan: Reg Z & RESPA
Compliance Buzz Offline
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Joined: Feb 2002
Posts: 319
NJ
Titled, manufactured home on leased land: does Reg Z and RESPA disclosures apply the same as it would on a 1-4 family home? Loan department is closing loan as an auto because it's titled rather than mortgaged - which I'm concerned the higher rate would trigger predatory lending (is this a legitimate concern?). We've never done one of these before - any guidance would be helpful.
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#1023823 - 08/20/08 02:09 PM Re: Manufactured Home loan: Reg Z & RESPA Compliance Buzz
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
If it's for consumer purposes Reg Z does apply, however RESPA doesn't, which includes rescission. For RESPA you have to have 'dirt'.

Yes, I would be concerned also if I were you.
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#1023867 - 08/20/08 02:37 PM Re: Manufactured Home loan: Reg Z & RESPA Skittles
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Compliance Buzz, you need to look to the definition of a dwelling at 226.2(a)(19). This loan is also subject to the flood rules and HMDA reporting.
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#1023877 - 08/20/08 02:44 PM Re: Manufactured Home loan: Reg Z & RESPA Dan Persfull
Oursisnottoreasonwhy Offline
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Oursisnottoreasonwhy
Joined: Nov 2004
Posts: 503
Central Illinois
Reg Z Section 32 is a legitimate concern. I believe the triggers are $583 in fees or 8% of the loan amount for 2009 and APR of 8% over comparable treasury rate.
Last edited by Oursisnottoreasonwhy; 08/20/08 02:56 PM.
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