We have two Commercial Loans for the purchase of a Manufactured Home Community that includes the purchase of the park, club house, etc. We have the loans classified as CRA community development, based on the area housing and middle income middle income census tract. Are the loans also HMDA reportable as manufactured housing, 1-4 family, or multifamily?

If you are not financing any of the actual dwellings, then it would not be reportable for HMDA. If your loan financing the mobile home for the park manager, then it would be reportable at 1-4, manufactured home.

Just curious as to how this loan would be considered Community Development basedon a middle income census tract. Is it an underserved census tract? Do you have documentation to back up that the homes will provide affordable housing for low- and moderate-income persons?

Also, if the loan is $1Million or less, you may have to report this as a small business loan since the mobile home park (club house, pads, etc.) would be considered non-farm/non-residential property. (Odd, I know, but only the mobile homes themselves are considered to be residential. Everything is basically a big rental lot.)

Thank you for your response. To qualify the loan for community development we researched other housing in the area. The research indicates that the average home payment in the area is $1800/month vs. the average cost of units in the park is $500/month, that includes lot rental.