Academic journal article ABA Banking Journal

Handling Mobile Home Loan Paperwork

Academic journal article ABA Banking Journal

Handling Mobile Home Loan Paperwork

Article excerpt

Q. We finance mobile home purchases--the home only, not the land.

I know that the Mortgage Disclosure Improvement Act (MDIA) states that a bank must provide "early disclosures" on these types of loans, but I don't see where it discusses what the "early disclosures" are. We provide good faith estimates on these types of loans, but we do not provide a HUD-1 at closing.

A third-party auditor (not one of our examiners) cited us for not providing the HUD-1.The firm said that we either need to not give the GFE or start giving the HUD-I. What are your thoughts?

A. In the loan transaction you describe, the MDIA "early disclosures" required under Regulation Z, section 226.19(a) for a mortgage transaction subject to RESPA, do not apply. If the transaction is not subject to the Real Estate Settlement Procedures Act, then neither an "early TIL" nor a GFE is required. Some argue that providing either or both the GFE and HUD-1, when not required, is permissible if they are provided "for informational purposes. …

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