We are taking a mobile home as collateral on a debt consolidation loan. None of the debts to be paid by the loan are for a dwelling. It is owned free and clear. Does that keep it from being a HOEPA loan as not being a refi of the dwelling?

Nope - From 1026.32: Coverage. (1) Except as provided in paragraph (a)(2) of this section, the requirements of this section apply to a consumer credit transaction that is secured by the consumer's principal dwelling.

If your loan is consumer purpose and the mobile home is the applicants principal dwelling, it would be subject HOEPA if it meets the rates and/or fees test.