HMDA - Classify Loan as 1-4 or Mobile home?

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Question:

I have a HMDA loan on a mobile home where the title is being retired. The title is being retired because the mobile home is now permanently affixed to the property and will be classified as a 1-4 family dwelling. I need to know how to classify this loan for HMDA: 1-4 family dwelling or Mobile home? Also, I was wondering where I could find some literature on the retirement of a title.

Answer:

I'm not familiar with retirement of a title, so I won't be able to help you with that question.

The FFIEC has published a series of Frequently Asked Questions that you find here. The first question deals with Modular Homes. It states: Answer: For Regulation C reporting, a manufactured home is one that meets the HUD code, 12 CFR 203.2(i). The official staff commentary indicates that modular homes that are ready for occupancy when they leave the factory and meet all of the HUD code standards are included in the definition of "manufactured home". 203.2(i)-1. The comment, and a prior FAQ on this site, have raised questions about whether a modular home should be reported as a manufactured home or as a one- to four-family dwelling. Until the Board provides further guidance regarding modular homes, lenders may, at their option, report a modular home as either a one- to four-family dwelling or as a manufactured home. You are safe to report this as a 1-4 family dwelling.

First published on BankersOnline.com 3/13/06