Are we sure the purchase agreement doesn't include some mobile homes? If the seller of the property owned some units to rent (as opposed to just the lots), then I think your analysis takes on a different character.
If your borrower is only purchasing the land and the lot lease agreements, but no units themselves, then I agree with Lee & David.
Also, now is a good time to ask the borrower for any information on the average incomes of the renters, or whether any lots are set aside for LMI renters. We couldn't produce this data for our CRA examiners (FRB) on our lots-only park loans, so they wouldn't give us community development credit for the loans.
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- Bart Jonker, CRCM
Opinions stated are not legal advice, and are not necessarily the opinions of OAK Financial Corp.