We do loans secured by a mobile home, 1st lien, vacation home. We do not take the land as the lots are in a park that is only open in the summer. Lot's are rented. Do we need to enter the rate spread info into the HMDA LAR since they are not subject to HPML or HOEPA?

If the loan is:

Subject to Regulation Z

and

The difference between the APR and the average prime offer rate is equal to or greater than 1.5 percentage points for a first-lien loan or equal to or greater than 3.5 percentage points for a subordinate-lien loan.

You would enter the rate spread info into the HMDA LAR.