The Truth in Lending Act (TILA) was set up to promote informed use of consumer credit and increase transparency by requiring disclosures about its costs and terms. A joint group of federal agencies that oversee truth-in-lending concerns, including the Consumer Financial Protection Bureau (CFPB), are proposing to amend Regulation Z, which implements TILA. The revisions include a provision added as part of Dodd-Frank that excludes loans for manufactured homes in communities from the definition of “higher-risk mortgage loan.” The Indiana Manufactured Housing Association (IMHA) reports some industry lenders say they would not be able to make more than half of the loans they currently make on manufactured homes without this exclusion. MHProNews has learned if the loan is secured by the home and the land on which it sits (italics added), it could be considered a “higher risk mortgage”. Public comment on the proposal will be open until Oct. 15, 2012. See pp. 14, 38, and 44 of the attached link to the entire document forwarded to MHProNews by D.J Pendleton of the Texas Manufactured Housing Association.
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