HMDA & RESPA on a Lot Loan?

Are we required to report HMDA information on a loan where we are taking a security interest in a lot which is owned by the borrowers, but not in the mobile home that sits on the property? The mobile home is being purchased on contract from an individual, and is not in the borrower's name. Does RESPA apply to this loan? The purpose of the loan is bill consolidation. We plan on documenting the file showing the purpose, and do not think either of these regulations will apply.