Q: We are taking a piece of land as collateral. The land contains a mobile home that is incidental to the loan (for example, the bank is not requiring insurance on the mobile home). It will be booked on the system as a “land-only” loan; we will take the mobile home as collateral by default. Is this loan reportable?
A: The manner in which you code the loan into your system generally does not determine if the loan is HMDA reportable. The primary question is whether this loan meets the definition of a home purchase loan or a refinancing under Regulation C. Section 203.2(h) defines a home purchase loan as a loan secured by and made for the purpose of purchasing a dwelling. Section 203.2(k) defines a refinancing as a dwelling-secured loan that satisfies and replaces a dwelling-secured loan to the same borrower. The definition of dwelling in §203.2(d) is a residential structure, including a mobile home or manufactured home. Because a mobile home is a dwelling under Regulation C, the loan would be reportable as a home purchase loan if the loan was used to purchase the land and the mobile home or reportable as a refinancing if the loan replaces another dwelling-secured loan with the same borrower.
This can be found in - HMDA FAQ#1 of the FAQs. The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/