I keep going back and forth between these answers which would be referring to the mobile homes that will be parked in the community (but are not actually part of the collateral) and just reporting "NA" for these because really, there is no actual "dwelling" tied to the loan. However, I struggle with using "NA" as well because this exemption isn't listed as a reason for any of these fields in the CFPB's "Reporting NA" chart. However, for the "Construction Method" field, you don't have an NA option, so I guess you would be required to put a "2- Manufactured Home" because that is the only logical answer (although sometimes I fell like trying to apply logic when determining HMDA reportablility is dangerous
). So, we could follow that same logic for the other fields as well and use what RRJoker suggested above. I just wish that they would have given us additional guidance on this if they were going to add it to the list of reportable transactions because we do quite a few of these Manufactured Home Community loans.