If the land was used to get the funds for the manufactured home, even free and clear it would IMO be a Home Equity. They could however be looking at it from section 1016.37(a)(6) in this section it speaks to a lot being owed already. Constructing the home in this case is the construction phase and the permanent phase is then referred to as a refinance. How, I’m understanding what you stated is they already own the land and are getting a loan to purchase the home. Nothing is being “constructed” but transported after it was built elsewhere.
I agree that the descriptions used for disbursement may have been confusing to the auditor. But “manufactured/mobile/modular” home definitions in the Regs (HMDA, Flood, RESPA and HUD) define this dwelling as being constructed elsewhere and moved to a permanent place. With that being said, IMO it is not a site build so it is not a construction loan. Construction definitions in the same regulations already listed define construction as being built on the land (site build). Also, IMO if the borrower understood the original CD as you had it described and you were doing it that way for everyone, it was a consistent process. The fact you changed the terminology for an auditor, just make sure the process is still clear to the consumer.