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Property Type

The "Property Type" field requires lenders to identify the type of property being purchased, improved, or refinanced in the transaction. Separate codes are provided for 1-4 family, manufactured, and multifamily secured loans so that analysts may better understand the underwriting process used when making a credit decision. Segregation by property type may also help to explain differences in denial rates.

WHAT IS MANUFACTURED HOUSING?

Manufactured housing means any residential structure as defined under 24 CFR 3280.2 of the Department of Housing and Urban Development regulations establishing manufactured home construction and safety standards. The HUD definition refers to housing that is essentially ready for occupancy when it leaves the factory.

REPORTING PROPERTY TYPE ON THE HMDA-LAR

See the “property type” field on the LAR and the codes for filling it out.

For reporting purposes, use one of the following three choices:

Code 1 – One to four-family (other than manufactured housing)
For loans or applications related to one- to four-family dwellings, including loans on individual condominium or cooperative units. Also, use this code if it cannot be determined whether the loan or application relates to a manufactured home.

Code 2 – Manufactured housing
For loans or applications related to manufactured housing.

Code 3 – Multifamily
For loans or applications related to a multifamily dwelling.

EXAMPLE ONE: COVERED LOANS

FACTS: Bank of Rural America makes a $15,000 loan for the purchase of a camper that will be permanently parked on a parcel of land owned by the borrower. The camper is old and will not sufficiently collateralize the loan. The bank takes a second mortgage on the parcel of land.

QUESTION

Is this loan a covered loan under the definition of manufactured housing? (Hint: Is this camper considered a dwelling?)

ANSWER

The lender must determine if a camper is considered a dwelling. The official staff commentary to Regulation C specifically excludes recreational vehicles such as boats and campers. In this example, a “fifth-wheel travel trailer” is not considered a dwelling and, therefore, this transaction is not covered by HMDA.

EXAMPLE TWO: REPORTING REQUIREMENTS FOR MANUFACTURED HOMES

FACTS: Bank First originates a $55,000 loan for a mobile home. The loan is secured only by the mobile home.

QUESTION

Is this loan HMDA reportable and, if so, how will it be reported given the new rules?

ANSWER

The loan meets the definition of a loan to purchase a dwelling. The dwelling, in this case, is a manufactured home under the HUD definition.

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