MRAA joined with the National Marine Bankers Association to voice strong concern about a recent proposed rulemaking by the Consumer Financial Protection Bureau that would adversely impact the ability of liveaboards to obtain financing on boat purchases.

In a letter responding to a Federal Register docket, MRAA President Matt Gruhn and Chairman Dave Foulkrod expressed their concern that the definition of “dwelling” would include houseboats, and other vessels and vehicles in a new rule being written to enforce the Congressionally passed Dodd-Frank Bill. This new definition would have the effect of severely reducing the availability of credit to individuals who live aboard boats.

“The problem, as we see it, is marine lenders often times do have the expertise or ability to lend on marine loans and the new definition of ‘dwelling’ complicates the issue,” said Gruhn and Foulkrod in the letter. By including liveaboard vessels as dwellings, marine loans issued to these individuals will be exposed to the disclosure requirements of Dodd-Frank intended for real property.

MRAA is concerned too few lending institutions are currently writing boat loans, and this change to established procedures will reduce further the number of organizations willing to make boat loans.

MRAA asked the CFPB to re-consider its language defining “dwelling” so as not to severely reduce the availability of credit to the group of people who choose to live aboard a boat.