Refinance of Manufactured Housing

We are a mortgage bank with a somewhat significant manufactured housing division. A question that continues to arise deals with whether a manufactured home is a purchase or a refinance if the borrower owns the land before purchasing the manufactured home. For our secondary market investors, we show the transaction as a refinance of the land loan with improvements. For compliance purposes, I view this transaction as a purchase or a residential mortgage transaction. As the land owner did not live on the land before purchasing the manufactured home and attaching that home to the land, the loan transaction to fund the purchase of a manufactured home to attach to the land should be a residential mortgage transaction, correct? Or is it a refinance and we are stuck with Reg Z's ROR and HOEPA requirements? Also, the manufactured homes have significant discount points to lower the rate which hurts for HOEPA if the loan is a refinance.