Comment Submitted by Michael Bradley, PMHA

The provisions of this Act treat all loan activity for a "dwelling" in the context of it being a residential mortgage loan, secured by a mortgage, deed of trust, or other consensual security interest. We in the Pennsylvania Manufactured Housing association have a fire storm over HUD's inability to clearly define a chattel loan in the context of this Act. In Pennsylvania, Manufactured Homes-those built to the HUD code are financed as both real property mortgages and as chattel loans when placed on property not owned by the purchaser. These homes are sold by retailers licensed by the Dept. of Motor Vehicles and with the Pa. Dept. of Banking under the Motor Vehicle sales finance Act. the Chattel loan is typically a higher priced loans than a conventional mortgage due to the additional risk of not being able to perfect a lien on the real estate. the loans are written on third party installment sales contracts and motor vehicle titles are the means of perfecting the liens. Our retailers are being faced with a duel licensing requirement and excessive costs, to comply with these rules. What we would like you to address is a clear definition and procedures for the Chattel Loans. The Retail dealers do not negotiate rates and terms, these are set by the lenders. Also rates and terms for Chattel loans do not change daily, weekly or even monthly, they are much more stable than mortgage rates and terms. Chattel loans have their own distinct characteristic's and should not be included in this ACT.