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Application or Loan Data

Property Type

Prior to the current Regulation C revisions, manufactured housing was considered a one- to four-family building. It was reported as a home purchase, home improvement or refinancing loan of a one- to four- family dwelling in the “purpose” field of the loan/application register (LAR). The revisions add a new field, “property type,” and require lenders to identify the type of property involved in the transaction. The separate code for manufactured housing was added because these loans are underwritten differently from other types of housing loans and tend to have higher denial rates. Segregating these loans will help 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.

The reporting requirements add a new data field and additional codes under the “property type” field. 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.

Prior to the revisions, the lender would treat a loan for manufactured housing as a one- to four-family dwelling and would report it as a home purchase of such a dwelling in the “purpose” field. Under the revised rules, the “property type” field has been added to denote the type of property involved in the transaction. In this instance, the lender would report a Code 2 for manufactured housing in the “property type” field.

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