The specific part of the commentary you reference is 12 CFR § 1003.2(f)-2, “…A loan related to a manufactured home community is secured by a dwelling for purposes of § 1003.2(f) even if it is not secured by any individual manufactured homes, but only by the land that constitutes the manufactured home community including sites for manufactured homes…”
Unless the land you have mentioned is a manufactured home park/community, I believe you are describing a land secured loan where the proceeds are being used to purchase a manufactured home. Since the no dwelling is the loan, the loan would not be reportable.