Does a loan to refi a manufactured home (no real estate) fall under HOEPA?

Yes.

HOEPA is applicable to any loan secured by the borrower's principal dwelling unless it meets one of the exemptions in 226.32(a)(2) - manufactured homes meet the definition of a dwelling.

Yes. You are looking at the fact that you're taking a security interest in the consumer's principal dwelling, not if real estate is involved. Also, the fact that it is a re-fi is a key indicator that the loan should be checked for HOEPA.

Basically, if it falls under Reg Z and it's not a residential mortgage transaction, reverse mortgage, or HELOC it should be checked for HOEPA.

Can I tack on a question? I've got a mobile home refi (no dirt) that somehow squeaked through doc prep without a HOEPA worksheet. We caught it in loan review (failed the rate test) and sent the borrower a letter adjusting the terms to get the loan within regulation instead of having them sign all new docs. How should I report this?

I assume you're asking how you report it in your compliance/audit report - I would report it as a violation and report the corrective action taken.

Sorry - I should have been more specific (although I will make a note of that recommendation). I'm trying to decide how to report the loan for HMDA. Do I report the original terms of the note or the modified terms that make it no longer a HOEPA loan?

It would be my opinion because the loan was subject HOEPA at origination that you would report it as such. Modifications are not reportable.

Thanks! That was my thought but I just wanted to make sure.