Mobile Home Title Held As Security: Does HOEPA Apply?

Question:

Does the HOEPA test apply if I am doing a loan on a mobile home that is the borrower's primary residence but only the title is held as security? No mortgage (only a lien on the title) or land is involved.

Answer:

If you have a mobile home title as collateral, your loan is covered by HOEPA (assuming you have a RegZ covered borrower and purpose and you meet the HOEPA APR or Points and Fees tests). To review HOEPA coverage, refer to Section 226.32(a)(1) and Section 226.32(a)(2).

First published on BankersOnline.com 6/30/03