In the following situation, here is what we advise:
- Purpose = purchase a mobile home (non-owner occupied)
- Collateral = subordinate lien personal residence (owner occupied)
- Business or commercial purpose = primarily for a business or commercial purpose
You should understand that the property securing the loan would be reported for property location and property address. Should other fields be reported based on the property being purchased or the property securing the loan – see chart below:
| Field | Purchase of Mobile Home | Property Securing Loan |
|---|---|---|
| Construction Method | Manufactured Home | Site Built |
| Occupancy | Non-Owner Occupied | Owner Occupied |
| Lien Status | Subordinate Lien | |
| Property Value | 18,000 | 50,000 |
| Manufactured Home Secured Property Type | Manufactured Home and Not Land | N/A |
| Manufactured Home Land Property Interest | Direct Ownership | N/A |
The HMDA Guide and HMDA Charts reference either the “the property securing the covered loan” or the “Identified Property” for each data point. We know this causes some confusion. The answer is that they are both the same!
“For purposes of this guide, the property for which the Financial Institution has provided the address and location for these data points is called the Identified Property. “
So, the following data points/fields are reported based on the “Property Securing the Covered Loan” or the “Identified Property”:
- Loan Purpose
- Construction Method
- Occupancy Type
- Property Address – Street Address, City, State, Zip Code
- Property Location – County, Census Tract
- Lien Status
- Property Value
- Manufactured Home Information – Secured Property Type, Land Property Interest
- Total Units
- Multi-Family Affordable Units
- Combined Loan-to-Value
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