[gllewis]

We have a loan secured by 2 properties (1- primary residence single family dwelling & 2 – manufactured home on real property) For the property location we chose to report the primary residence. For the total number of units, do we include the manufactured home as well?

[jholzknecht]

Section 1003.4(a)(31) requires reporting of the total number of individual dwelling units related to the property securing the covered loan. When more than one property is taken as security, a financial institution reports the covered loan in a single entry on its LAR and provides the information for one of the properties taken as security that contains a dwelling. You simply choose one of the properties and report the number of units in that property.

[srhodes]

1003.4(a)(9)(2) explains what is expected for reporting total units.
For aspects of the entries that do not refer to the property identified in § 1003.4(a)(9) (i.e., § 1003.4(a)(1) through (4), (7), (8), (10) through (13), (15) through (28), (31) through (38)), Financial Institution A reports the information applicable to the covered loan or application and not information that relates only to the property identified in § 1003.4(a)(9).

This is interpreted that you would report total units securing the loan, not just what is related to the property reported.

[jholzknecht]

Agreed.

[Gholloway]

So are you saying that in this example you would report “2” for “Total Units”? Even though they are separate units securing the loan and only reporting the address information on one of the units?

[srhodes]

Yes, my interpretation is that you report the number of units securing the loan. In your case, 2.

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