GMI for Mobile Home Loans

Question:

Our compliance department has determined that GMI is not required for mobile home loans without land. Is this correct?

Answer:

I'm not sure of their reasoning. Land has nothing to do with GMI collection.

Section 202.13(a) (Regulation B) requires collection of GMI whenever a loan application is received for the purpose of purchasing or refinancing the borrower's primary dwelling. There is no exemption for "no land" loans.

Section 203.4(a)(10) (Regulation C) requires collection of GMI for HMDA applicable loans. HMDA specifically indicates a dwelling includes any "residential structure (whether or not attached to real property) . . ."

First published on BankersOnline.com 9/20/10