I researched some previous posts to determine if mobile homes without land are subject to HOEPA. Based on the definition of dwelling in Reg Z, it would appear that they are subject to HOEPA. Using this logic, I believe that a boat or travel trailer could also be subject to HOEPA if they are used as the borrower's primary residence. Is this correct?

If the loan is secured by the borrower's principal dwelling then it is subject to Sec. 32 just as it is subject the ROR.