I am looking for a second opinion on a loan transaction I believe to be HMDA reportable. The loan is to a “resort” that includes 25 RV hookups, 11 tent sites and 41 “recreational” mobile home sites. There is also a general store and typical improvements for this type of property. The resort does not own the mobile homes. These homes are likely used as second homes or “cabins” and are not park models. The tenants who own the mobile homes pay lot rent annually. I believe these 41 sites constitute a manufactured home community. The loan officer is arguing it is a “resort” since the tenants have to be offsite for two consecutive weeks during the year. I believe this is irrelevant to HMDA applicability. In a mixed-use situation, the purpose is hospitality, but the majority use of the property are those MH units. Thoughts?

The tenants who own the mobile homes pay lot rent annually....These homes are likely used as second homes .

IMO that makes it a MH community.