While the TRID rules and Regulation X do not apply to a loan secured by a mobile home that is not also secured by land, there are certain provisions of Regulation Z that do apply.

Under Regulation Z, you should provide an interest rate and payment summary, together with a specialized disclosure required for non-TRID mortgage loans – at or before the loan closing. Additionally, other Regulation Z disclosures required for loans secured by a dwelling generally will apply to a loan secured by a mobile home. For example, you should provide a notice of the right of rescission if the mobile home securing the loan is the borrower’s principal residence.

Note that this guidance does not relate to manufactured homes attached to the underlying land.

For resources related to our guidance, please see:

• Regulation X, 12 CFR 1024.2 (“Federally related mortgage loan means: Any loan (other than temporary financing, such as a construction loan): That is secured by a first or subordinate lien on residential real property. . . .”)

• CFPB Small Entity Compliance Guide, TILA-RESPA Integrated Disclosure Rule, page 12 (“The final rule applies to most closed-end consumer mortgages. It does not apply to home equity lines of credit (HELOCs), reverse mortgages, or mortgages secured by a mobile home or by a dwelling that is not attached to real property (i.e., land).”)

• Regulation Z, 12 CFR 1026.2(a)(19) (“Dwelling means a residential structure that contains one to four units, whether or not that structure is attached to real property. The term includes an individual condominium unit, cooperative unit, mobile home, and trailer, if it is used as a residence.”)

• Regulation Z, 12 CFR 1026.18(s) (“Interest rate and payment summary for mortgage transactions. For a closed-end transaction secured by real property or a dwelling, other than a transaction that is subject to § 1026.19(e) and (f), the creditor shall disclose the following information about the interest rate and payments: . . .”)

• Official Interpretations, 12 CFR 1026, Paragraph 18(s), Comment 4 (“. . . . 1026.18(s) governs only closed-end reverse mortgages and closed-end transactions secured by a dwelling that is personal property (such as a mobile home that is not deemed real property under State or other applicable law).”)

• Official Interpretations, 12 CFR 1026, Paragraph 15(a)(1), Comment 5 (“ . . . . Dwelling, as defined in § 1026.2, includes structures that are classified as personalty under state law. For example, a transaction secured by a mobile home, trailer, or houseboat used as the consumer’s principal dwelling may be rescindable.”)