Answer:
For HMDA, a boat house can be a dwelling. The question is what is it used for? If it's used for recreational purposes, then it does not meet the definition of dwelling.
"Recreational vehicles such as boats or campers are not dwellings for purposes of HMDA. Also excluded are transitory residences such as hotels, hospitals, and college dormitories—whose occupants have principal residences elsewhere. [Commentary to 1003.2]
If it's used as a residence, then it is a dwelling.
Note: The proposed hMDA rules (comment period ended in Oct 2014) will be excluding boathouses.
From the Section by Section Analysis (page 65-66):
"Regarding houseboats and floating homes that may be used as residences, certain financial institutions in areas where houseboats and floating homes are more common report loans related to floating homes and houseboats on their loan application registers. These institutions may receive consideration under the CRA for financing houseboats or floating homes. The Bureau recognizes that while these loans may provide housing for certain communities, the Bureau believes that financing of such loans is different from other home loans and the incidence of such housing is highly localized. Unlike manufactured housing, discussed below, usage and financing of houseboats and floating homes is not as prevalent, and the small number of houseboats used as residences suggests that loans secured by such properties should not be included in HMDA data. Therefore, the Bureau believes that excluding houseboats and floating homes will facilitate compliance with HMDA. However, the bureau solicits feedback on whether these exclusions are appropriate."
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