Posted By: Kompliance
Manufactured Home Community Loan - 11/10/17 03:46 PM
On page 27 of the CFPB's HMDA Small Entity Compliance Guide for 2018 data collection rules, it states:
"A loan related to a Manufactured Home community is secured by a Dwelling even if it is not secured by any individual manufactured homes, but is secured only by the land that constitutes the manufactured home community."
So, this would be the only time in all of HMDA World where we would report a "land only" loan coming in 2018. My question is, when we have a loan like this we have to report, what are we to report for all the fields that are in relation to the building securing the loan? Such as:
Construction Method
Occupancy Type
Manufactured Home Secured Property Type
Manufactured Home Land Property Interest
Total Units
Multifamily Affordable Units
Do you think we report "NA" for all of these, because there are no buildings securing this loan, just the land? Of course, the CFPB gave us that random blurb, and then omitted any further clarification.
"A loan related to a Manufactured Home community is secured by a Dwelling even if it is not secured by any individual manufactured homes, but is secured only by the land that constitutes the manufactured home community."
So, this would be the only time in all of HMDA World where we would report a "land only" loan coming in 2018. My question is, when we have a loan like this we have to report, what are we to report for all the fields that are in relation to the building securing the loan? Such as:
Construction Method
Occupancy Type
Manufactured Home Secured Property Type
Manufactured Home Land Property Interest
Total Units
Multifamily Affordable Units
Do you think we report "NA" for all of these, because there are no buildings securing this loan, just the land? Of course, the CFPB gave us that random blurb, and then omitted any further clarification.