HMDA reportable???

Posted By: bowlngirl

HMDA reportable??? - 09/10/21 03:24 PM

Customer is getting a loan to pour foundation on land he already owns. He will then move in a modular home which he already owns as well. Is this HMDA reportable and what would the loan purpose be?????
Posted By: raitchjay

Re: HMDA reportable??? - 09/10/21 05:09 PM

Not reportable in my opinion. Definitely not purchasing a home or refinancing a home. Some might make the argument for home improvement i suppose, but i don't think that flies since the home won't even sit on the property until AFTER your loan proceeds are applied (in other words, it isn't improving the real property on which the dwelling is located, because the dwelling isn't located there).
Posted By: raitchjay

Re: HMDA reportable??? - 09/10/21 05:10 PM

(You don't mention what your collateral is, but i assumed the home to be part of the collateral...otherwise, the question would be moot anyway.)
Posted By: raitchjay

Re: HMDA reportable??? - 09/10/21 05:40 PM

Well....i see that i was operating on my old HMDA brain again. If this loan would indeed be secured by the modular home, it WOULD be reportable....as an "other" in my opinion (assuming that this is a consumer purpose loan). Sorry for the memory lapse.
Posted By: bowlngirl

Re: HMDA reportable??? - 09/10/21 05:44 PM

The collateral will be the land. I have a call in to see if we will be taking the modular as well.
Posted By: raitchjay

Re: HMDA reportable??? - 09/10/21 05:47 PM

I believe in most all states, modular homes aren't titled.....so you would by definition (unless your state is different, and the modular home is and will remain titled, and you won't have a security interest in it) have a security interest in the dwelling too. So i hold to my opinion in my last post.....reportable as "other". I feel pretty certain there are going to be those who argue for "home improvement".
Posted By: raitchjay

Re: HMDA reportable??? - 09/10/21 05:49 PM

And honestly.....i might could be swayed to HI.....i can see the argument.