We have a past due customer that collections is considering for repossession. I was asked about it because they are concerned because they have discovered the customer has been using this property as a residence. Scenario: Customer has a note to refi a truck and purchase a travel trailer. He uses the travel trailer for living quarters when he travels for work. (He sold his primary residence in 2021, before getting the loan for the travel trailer.) The loan was written for a truck and travel trailer, both titled, and the trailer as a non-residence travel trailer. However, since the trailer is being used for a residence, the collections guy called about the requirements for repo, including if the 120-day foreclosure rule would apply. Should it? This wasn't a mortgage loan. But, since there's a residence involved, does that change the situation?

If there is no land involved, the loan is not subject to RESPA.

You should check with counsel on this. As Randy notes, RESPA doesn't apply, but you want to be very careful about repossessing someone's home even if it's on wheels.