[Sandy]

We have a applicant who already owns their land with no liens. They want to purchase a mobile home to live in and move to the property. I understand for TRID purpose this will be treated as a Home Equity loan and not a purchase. Do we mark GmI? We are a non HMDA bank.

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[jholzknecht]

Regulation B requires the collection of monitoring information for the purchase or refinancing of a dwelling occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling.

If your loan is secured by the mobile home and if the mobile home will be the consumer’s principal dwelling, it appears GMI must be collected.

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