We believe that RESPA would apply to a loan secured by land and by a mobile home. The RESPA regulations state that they apply to loans secured by vacant land if “a structure or a manufactured home will be constructed or placed on the real property using the loan proceeds” within two years after the loan closing. 12 CFR 1024.5(b)(4).

Also note that Regulation Z would apply to a loan secured by a mobile home. It applies to loans “secured by any real property, or by personal property used or expected to be used as the principal dwelling of the consumer.” 12 CFR 1026.3(b)(1)(i)(A). The staff commentary confirms that mobile home loans are covered by Regulation Z, provided that the mobile home “is used or expected to be used as the principal dwelling of the consumer.” Comment 5, Official Staff Commentary, 12 CFR 1026.3(b).