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HMDA and the Mobile Home Park

Question: 
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?
Answer: 

by Dan Persfull:

No.

First published on BankersOnline.com 5/2/05

Answer: 

by John Burnett:

Dan's response was correct when this page was published in 2005. HMDA regulations were completely overhauled effective 1/1/2018, and a manufactured home community is now considered a "dwelling" under the new regulations. Under comment 2(f)-2, we find "A loan related to a manufactured home community is secured by a dwelling for purposes of § 1003.2(f) even if it is not secured by any individual manufactured homes, but only by the land that constitutes the manufactured home community including sites for manufactured homes. However, a loan related to a multifamily residential structure or community that is not a manufactured home community is not secured by a dwelling for purposes of § 1003.2(f) if it is not secured by any individual dwelling units and is, for example, instead secured only by property that only includes common areas, or is secured only by an assignment of rents or dues."

Thus, if the "mobile home park" in the question is a "manufactured home community," the loan will be secured by a dwelling under current HMDA rules, and reported.

First published on 05/02/2005

Last updated on July 25, 2018

Filed under: 
Filed under lending as: 

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