Manufactured Home Secured Property Type & Manufactured Home Land Property Interest
Beginning in 2018, a financial institution will report manufactured home information as part of their HMDA data. Specifically, the secured property type and the land property interest information should be reported in regards to the manufactured home that is securing the loan.
For the secured property type, a financial institution will have to report whether the loan is secured by a manufactured home and land or if the land is not securing the loan. A financial institution will report that the Manufactured Home is not secured by land even if the Manufactured Home is considered real property under state law.
For the land property interest, the financial institution should report the information about the applicant’s ownership interest in the land where the manufactured home is located. The first option that can be reported is direct ownership. This is used when the applicant has direct ownership in the land and the ownership is more than a possessory real property ownership interest. Another option is indirect ownership. This is reported when the applicant is a member of a resident-owned community that is structured as a housing cooperative which owns the underlying land. If the applicant lives in a resident-owned community but is not a member, the land property interest would be reported as a paid leasehold. A paid leasehold can occur when the applicant does not have an ownership interest in the land but they have a written lease for the lot that specifies rent payments. This data point can also be reported as an unpaid leasehold. This occurs when there is no written lease and therefore no agreement for rent payments.
There is an additional circumstance for the land property interest data point. This will be reported as “not applicable” if the location for the manufactured home has not yet been identified at the time action was taken. When it comes to reporting these data points as “not applicable” on your HMDA LAR, there is some overlap. Both of these data points will be reported as “not applicable” when the dwelling that is securing the loan is not a manufactured home or if it is a manufactured home community that is a multifamily dwelling.
For more information on HMDA regulations, 2018 data point changes or our HMDA compliance services, please call Rhonda Wannemuehler or Betsy Reynolds at 855-734-7655.
Property Address, State, County, and Census Tract HMDA Reporting
Under the new regulation, the property address along with the state, county, and census tract data must be reported as part of your HMDA information. These data points must be reported if the property is located in an MSA or metropolitan division where the institution has a home or branch office. They should also be reported if the institution is a bank or savings association and they are required to report HMDA data on small businesses, small farms, and community development lending under the Community Reinvestment Act. The census tract has an additional reporting requirement as it is only reported if the property is located in a county with a population of 30,000 or more.
In order to determine which property data to report, the institution must look at which property is securing (or was proposed to secure) the loan. In the case where more than one property secures the loan, the institution should report the information for only one of the properties. If the property securing the loan is a single multifamily dwelling that has more than address, then just one of the addresses should be reported by the institution. In the instance where the property securing the loan is not known or the location for a manufactured home has not been identified, then the data point for the property address should be entered as being not applicable.
The majority of these data points can be determined by looking at the loan application; however, the county and census tract must be reported in numerical form. In order to determine what these values should be, the institution can enter the property address at: https://geomap.ffiec.gov
For more information on HMDA regulations, 2018 data point changes or our HMDA compliance services, please call Rhonda Wannemuehler or Betsy Reynolds at 855-734-7655.