Loan Scenario: HPML and disclosures

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Question:

I have a customer who wants to purchase a 4 acre tract of land with a mobile home and shop building on it. We will not have a lien on the mobile home, just the acreage and shop. I am under the assumption that RESPA does not apply since there is no lien on the dwelling. However I know it will be a HPML... so I have to escrow for property taxes, right? When do I have to send out TIL disclosures?

Answer:

If the loan is not secured by the consumer's principal dwelling, Section 226.35 does not apply, and if the loan is not subject to RESPA, Section 226.19(a) does not apply.

First published on BankersOnline.com 2/28/11