Questions and Answers

Do early truth in lending disclosures apply when consumer is purchasing a mobile home with no real property attached or involved?

Probably not. The early Truth-in-Lending disclosures are required by section 19 of Regulation Z (12 CFR 226.19(a)) Section 19 says that early disclosures are required if the loan is a residential mortgage transaction subject to RESPA. A loan is subject to RESPA only if it is secured by a lien on “residential real property.” A mobile home that is not attached to the ground is probably not considered residential real property.

(Posted: 05/16/2008)

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