Answer:
You don't say whether the new loan is secured by the mobile home, only that you still consider the loan a land only loan or if the loan is secured by a first or subordinate lien.
Since you are asking about having to escrow I will assume the loan would qualify as a HPML. Refer to 226.35(a)(1) for the loans subject to HPML requirements.
First published on BankersOnline.com 6/27/11