[smoon]

In our scenario, we have a customer who is buying a “Tiny House” from a manufactured home dealer. The purpose is to place the tiny house on family land to use for a vacation home. We aren’t taking the land as collateral but the tiny house will remain immobile. I contacted the HMDA help desk and received a “maybe, maybe not” non-answer.

I am leaning more toward treating this as a mobile home only loan, but the loan officer is wanting to treat it as a rv loan. Thoughts?

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[rcooper]

I don’t think there is any concrete answer that you will find on this so you may have differing opinions from examiners that look at this. With that in mind, I would consider it a dwelling and believe treating it as a mobile home would be fine. Keep in mind that even though it is a dwelling, it may not meet the definition of a manufactured home under Reg C.

[jholzknecht]

Interesting question. I agree with Robin’s comments. Assuming it does not meet HUD’s definition of “manufactured home,” I suggest reporting it as:
> Purpose – Code 1 – Home purchase
> Property Type – Code 1 – 1-4 family dwelling
> Owner Occupancy – Code 2 – Not owner-occupied as a principal dwelling

RV loan – really?

[Republic1]

I agree reporting as a home purchase loan as well (HMDA defines dwelling as a residential structure WHETHER OR NOT attached to real property), not owner-occupied (since it wont be their primary dwelling, but will be used as a secondary dwelling).
Your description doesn’t appear to fall into the “RV” category since the tiny house is immobile. While not a REGULATORY definition of a tiny house, I did find this site which begins to tell you when a tiny house is considered a dwelling versus an RV (per THEIR definitions of themselves), at: TinyHouseCommunity.com/FAQ.htm. It says: “legally, a tiny house on wheels is considered an RV, and a tiny house on a foundation is considered an accessory dwelling unit (ADU).” It might help to have that page printed for your file though.

I think you will need to gather all of the deminsions and attachments and set-up of the tiny house before even beginning to analyse if you would code it as a 1-4 family dwelling or as a manufactured home. Reg C points us to HUD’s definition and it outlines very specific requirements as shown below…

24 CFR 3280.2
https://www.gpo.gov/fdsys/pkg/CFR-2012-title24-vol5/xml/CFR-2012-title24-vol5-sec3280-2.xml
“a structure, transportable in one or more section which, in the traveling mode, is 8 body feet or more in width or 40 body feet or more in length, or, when erected on site, is 320 or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained therein.”

[Author]

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