Topic: Manufactured Homes
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If we have a loan secured by a mobile home that is treated as chattel property under Illinois law, what disclosures and timing requirements apply under Regulation Z? (The loan is not secured by land.)
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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…
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We have decided to make only qualified mortgages (QMs). One of our customers wants to purchase a motor home, and both the motor home and the customer’s house will be collateral for the loan. If the motor home is not considered as part of the loan collateral, we’re concerned that the loan would not be considered a QM due to a high loan-to-value ratio.
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We believe that a mortgage loan that qualifies as a qualified mortgage (QM) would not be disqualified simply because it is only partially secured by the borrower's home. Of course, the new Regulation Z ability-to-repay (ATR) requirements would apply to this loan. The ATR rules apply to consumer credit transactions secured by a “dwelling,” provided…
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Do RESPA and Regulation Z cover a loan that is secured by vacant land and by a mobile home that won’t be permanently affixed to the land?
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We believe that RESPA would apply to a loan secured by land and by a mobile home. The RESPA regulations state that they apply to loans secured by vacant land if “a structure or a manufactured home will be constructed or placed on the real property using the loan proceeds” within two years after the…
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Do the HPML regulations apply to a loan secured by a modular home?
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The higher-priced mortgage loan (HPML) regulations apply to any consumer loan “secured by the consumer’s principal dwelling” (assuming that the loan otherwise meets the “higher-priced” definition). 12 CFR 1026.35(a)(1). The term “dwelling” is defined as a “residential structure that contains one to four units, whether or not that structure is attached to real property. The…
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Was there a 2011 law that converted mobile homes from personal property to real property?
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The 2011 mobile home law (P.A. 96-1477) related only to the taxation of certain mobile homes as real estate under the property tax code. The IBA has been supporting legislation that would establish a formal method of converting a mobile home (referred to in the bill as a manufactured home) to real property for purposes…