Where would I find lending regulations and guidelines about consumer mobile homes loans, specifically regarding late charges?
Under the new HPML rules, most of our loans will be required to have the customer escrow for taxes, insurance, etc., for a minimum of twelve months. We handle mobile homes, and many times customers will pay their homeowner's insurance premium prior to closing for two to three years in advance. Practically all of these customers would seek to cancel their escrow requirements after the first twelve months has been reached. If this were to be the case, would an escrow account need to be established for the insurance portion, since they already paid the premiums?
I was told in the Reg Z, that mobile homes in communities (mobile home parks) were not included in the new disclosure practice of GFE in three days and then loan after seven days. Is this true?
What does the term "flood insurance" permanently affixed to real estate mean as it pertains to mobile homes needing flood insurance? If the bank took on the mobile home as collateral, and the mobile home that still has the tongue attached is not considered to be permanently affixed, does the mobile home not require flood insurance? Clarification is needed as to what constitutes that a mobile home has been permanently affixed versus not permanently affixed and/or anchored to a foundation.
Are houseboat loans considered 1-4 family residential loans or consumer loans?
Our bank has made a loan to a corporation that owns and operates mobile home parks. The purpose of the loan is to refinance one park with 150 pads. Some of the homes in the park are owned by the corporation and rented out to individuals, and some pads are rented to individuals that own their own mobile homes. Is this a CRA small business loan or a multifamily HMDA refinance loan?
Would a refinance or purchase of a Mobile Home Park, where we do not take any of the Mobile Homes as collateral, just the land, be HMDA reportable?
I have a compliance question regarding right of rescission. If a person's primary residence is a piece of land with a mobile home on that piece of land and the person applies for a loan using the land only as collateral, is a rescission period still required? I would think it would be since the property is that person's primary residence, even though the mobile home is not being used as collateral.
Following the old advice of something old, something new, the OCC has issued guidelines on establishing standards for national banks on mortgage lending.
When financing a mobile home lot, should a flood determination be done for the mobile homes on the lot?