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An appraisal is required for a higher-priced mortgage loan secured by a first lien on a consumer’s principal dwelling according to 1026.35(b). However 1026.35(c)(2) contains an exemption for a HPML secured by a mobile home. There is a partial exemption for a HPML secured by a manufactured home. Is your collateral a mobile home or a manufactured home?
In your case the appraisal requirement probably does not apply due to the mobile home exemption, the fact that the mobile home is apparently not a principal dwelling, and the loan may or may not be an HPML.