Process & Practice

Mobile home park due diligence in BC, the checklist I actually use

Most mobile home park due diligence checklists are written for American parks. They will tell you to pull the rent roll and walk the lots, and they will miss almost every item that changes a price in British Columbia.

15 min read

Pull the rent roll, walk the lots, check the utilities. That is the advice in every mobile home park due diligence checklist on the internet, and none of it is wrong. It is just written for a different country.

BC has its own water rules, its own sewage thresholds, its own registry for the homes themselves, and a property transfer tax that treats a park as residential. Those are the items I have watched change a price after an offer was already signed. Here they are in the order I work through them.

The water permit does not come with the park

If the park has its own well serving more than one home, it is a regulated water supply system. The Drinking Water Protection Act defines a water supply system as a domestic water system other than one serving only a single family residence. Two homes on one well clears that bar.

What that means in practice: section 8 of the Act says the water supplier must not operate the system without a valid operating permit, and the Drinking Water Protection Regulation prescribes every water supply system for that section. There is no small system carve-out from the permit itself, though small systems are let off some other duties, so do not read a small system exemption elsewhere as covering the permit.

Now the part buyers miss. Regulation section 7.2 says an operating permit or a decal is not transferable. The seller's permit is the seller's. You apply to the Drinking Water Officer at the regional health authority for your own, and you want that conversation started before closing rather than after. A permit in force on March 31 expires that day, and a permit without a current decal is not valid.

Ask for two years of sampling results, not the most recent one. Under Schedule B a system serving fewer than 5,000 people takes four samples a month, tested for total coliform bacteria and E. coli. Schedule A allows no detectable E. coli per 100 mL. A single clean month tells you nothing about a well that fails in spring runoff.

One more water item. Existing non-domestic groundwater users had until March 1, 2022 to apply for a licence and keep their historical date of first use. Anyone who missed it lost that option and sits in the queue as a new applicant. Whether a rental park's well counts as domestic use or as a licensable waterworks purpose is not clearly settled by the definitions in the Water Sustainability Act, so get a written determination from the regional water authorisations office. Do not accept the seller's read on it.

Two numbers decide who has to sign off on the sewage system

The first is 22,700 litres per day. Below that combined design daily domestic sewage flow, the system sits under the Sewerage System Regulation and the regional health authority. At 22,700 litres per day or more it moves to the Municipal Wastewater Regulation under the Environmental Management Act, and the Ministry of Environment becomes your regulator. Different regime, different cost, different timeline. One trap in that: the 22,700 litre floor only applies to discharge to ground. A system discharging to water sits under the Municipal Wastewater Regulation at any volume, so a small park discharging to a creek is already there.

The second is 9,100 litres per day. Section 6(3) of the Sewerage System Regulation says that unless supervised by a professional, nobody may construct or maintain a system using Type 3 treatment or one designed for an estimated minimum daily flow of more than 9,100 litres. So above that flow a registered onsite wastewater practitioner cannot carry the system alone. They can still do the work, but a professional has to supervise it, and a professional here means more than just an engineer. If the seller's paperwork on a system above that threshold shows an ROWP acting unsupervised, you have found something.

Two documents matter here. The section 8 filing, which includes the plans and specifications with the authorized person's seal on them plus the soil type, depth and porosity. And the section 9 letter of certification, which the authorized person must file within 30 days of finishing construction, with an as-built plan and a maintenance plan attached. If the letter is missing, the system was either never completed to standard practice or never certified. Both are your problem now.

You request those records from the health authority. Island Health charges $50 per property through its Request for Release of Information form and holds records from 2005 onward, with most files from 1990 to 2005. The health authority does not approve designs, it receives filings. So a quiet file is not a clean bill of health.

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Verify who owns each home, home by home

The rent roll tells you what the seller believes. The Manufactured Home Registry, run by BC Registry Services, tells you what is registered. In BC the sale, transfer or purchase of a manufactured home is only effective if the transaction is registered, and the registry holds the registered owner, location and description of each home.

A self-serve electronic search runs $7 plus a $1.50 operator fee. Add the Personal Property Registry, where a lien against a home would sit, and it is $12 plus the same fee. A search done for you by staff at a counter or by mail costs more, $10 and $15. On a 30 pad park you are looking at roughly $405 online to independently confirm who owns what and what is encumbered. I have never regretted spending it.

The tax treatment follows the same split. Under the Manufactured Home Tax Act a home is an improvement, and section 3(1) says that where the home is in a park and the home owner is not the park owner, the home is assessed and taxed in the name of the home owner. That is the tenant's bill.

Section 5(2) is the provision I like most in the whole statute. For those taxes, the park land is not subject to tax sale or forfeiture, and the arrears do not constitute a lien on the land. A tenant's unpaid home taxes cannot reach your land.

Two duties come with it. Section 6 requires the park owner or operator to furnish the assessor with full information about the owner of each home on demand, and to notify the assessor in writing promptly after a home is moved into or out of the park. And when a home does leave, the permit to move it requires a tax certificate signed by the tax collector with at least 30 days left to run, so taxes get settled first.

The closing tax bill is bigger than most models show

Property transfer tax runs 1% on fair market value up to $200,000, 2% above that to $2,000,000, and 3% above $2,000,000. Then there is a further 2% on residential property value above $3,000,000.

Here is why that further 2% catches park buyers, and it is the point most people argue with me about. A park is commercial real estate. You buy it on a cap rate, you finance it as commercial, and everyone in the deal calls it commercial. None of that is the same question as how BC Assessment classifies it. The Prescribed Classes of Property Regulation puts land and improvements used for residential purposes, manufactured homes included, in Class 1. Pads are used for residential purposes, so the land is Class 1 Residential. BC Assessment's own manufactured home properties policy says the same thing, that classification for parks must be Class 01 Residential except for areas in non-residential use, which get split out to their own class.

So the further 2% applies to essentially the whole park value above $3M, not to some small carved-out portion. Commercial asset, residential class. Both are true at once and the tax follows the class.

Run the arithmetic on a $4M park. General PTT is $98,000. The further 2% on the $1M above the threshold adds $20,000. That is $118,000 at closing on published rates.

Foreign buyers have a larger problem. The additional property transfer tax of 20% applies in the Capital Regional District, Fraser Valley Regional District, Metro Vancouver Regional District, Regional District of Central Okanagan, and Regional District of Nanaimo. Where a property is entirely Class 1, the tax is based on the fair market value of the entire property. On that same $4M park in Central Okanagan, that is another $800,000.

On GST, pad rent in a residential trailer park is an exempt supply where the arrangement gives continuous possession of the site for at least a month. Ordinary pad tenancies clear that; short-stay sites do not. The sale of the park is a different question, and it turns on how the vendor acquired it and whether input tax credits were ever claimed on the park or on improvements to it. Get a GST opinion on the actual chain of title. Anyone telling you there is no GST because it is residential has not looked at the vendor's acquisition history.

The charge on title that follows the park to you

The usual title search work applies: charges, liens, easements, statutory rights of way. The charge worth reading closely is a section 219 covenant under the Land Title Act, which is enforceable against successors in title even where it is not annexed to land owned by the covenantee, and which can restrict how land is used, whether it can be built on, and whether it can be subdivided.

Why that matters for a park specifically. West Kelowna's manufactured home park redevelopment policy requires an applicant to enter into a section 219 covenant to secure tenant relocation plan requirements. So a tenant relocation obligation can be registered on title and it binds you as the next owner.

If the park sits in the ALR, slow down

Start with the statute rather than the seller's assurance, and skip the section everyone reaches for first. The Agricultural Land Commission Act defines non-farm use as a use other than a farm use, a residential use, or a soil or fill use, so the homes themselves are not caught by the section 20(1) non-farm use prohibition. The provision that actually bites is section 20.1(1)(a), which allows agricultural land no more than one residence per parcel. A park is many residences on one parcel. The ALR Use Regulation does not mention manufactured home parks anywhere. A park in the ALR is relying on Commission permission or on lawful pre-existing status, and expansion is a real question rather than a formality. Confirm which one applies, in writing, with the Agricultural Land Commission.

If you are buying through a corporation, trust or partnership, budget time for the Land Owner Transparency Registry. Each transferee must file a transparency declaration on an application to register an interest in land, and a reporting body must also file a transparency report.

Check whether you are accidentally a utility

If you resell electricity to tenants, the Utilities Commission Act keeps you out of public utility status through an exclusion for someone supplying a commodity only to their own tenants where it is not resold to or used by others.

The catch is in the definitions. Under that Act, tenant does not include a lessee for a term of more than 5 years. BC Hydro's own advisory on resale puts it plainly: reselling to tenants on leases of no more than five years is not a public utility, and reselling on a lease greater than five years is, unless an exemption applies. The BCUC has granted a class exemption covering BC Hydro customers who resell under certain lease arrangements, so check whether you land inside it. Read the actual pad lease terms before you assume any of this covers you, and treat the advisory as guidance rather than law, which is what it says of itself.

BC Hydro's electric tariff also caps what you can pass on at what BC Hydro would have charged the tenant as its own customer, and requires you to keep resale records for 24 consecutive months.

Water sits with a different regulator entirely. Under the Water Utility Act a water utility supplying water for compensation to five or more persons is subject to the Comptroller of Water Rights rather than the BCUC, with the same tenant exclusion and the same five year limitation.

The environmental filing that catches older parks

A site disclosure statement gets triggered where a site has been used for an industrial or commercial use listed in Schedule 2 of the Contaminated Sites Regulation. On the sale itself it often will not be required, because Division 3 of that regulation exempts real property used primarily for a residential purpose, or never zoned for anything other than primarily residential. A park usually fits.

Do not read that as a free pass. The obligation still lands when you apply for a rezoning, a subdivision or a development permit, which is exactly what a redevelopment play involves. So the filing you dodged at closing arrives the moment you try to do anything with the land.

The Schedule 2 entries that turn up on older parks are petroleum product storage in non-mobile above ground or underground tanks, petroleum product dispensing facilities, septic tank pumpage storage or disposal, sewage lagoons or impoundments, and vehicle repair, salvage or wrecking. The tank entry carves out above ground tanks with secondary containment and those serving emergency generators, so how a tank is actually set up decides whether it counts.

Two of those describe a park's own sewage infrastructure. If the park runs a sewage lagoon, that is a Schedule 2 use sitting in plain sight.

Municipal zoning does not get you out of it. The Ministry is explicit that where a commercial activity takes place on residential or agricultural land, regardless of zoning, the activity must be declared as a Schedule 2 use. Also worth pricing fresh: fees for site remediation services changed on July 1, 2026.

Audit every rent increase notice in the file

Ask for the rent roll, every written tenancy agreement, the park rules, and the record of every rent increase with proof of how it was served. Then audit the increases against section 35 of the Manufactured Home Park Tenancy Act: no increase within 12 months of the last one, at least three months notice, in the approved form.

Section 35(4) is the one that costs money, and its reach is narrower than people assume. Where a notice misses the 12 month gap or the three month notice period, it does not disappear, it slides to the earliest date that does comply. That rescue does not extend to a notice given on the wrong form, which simply fails. So the rent the seller shows you may not be the rent legally in place, and the gap comes out of your NOI.

The RTB search you cannot run

You mostly cannot search Residential Tenancy Branch decisions by park name or address. The RTB does not include names, addresses or other identifying information in direct request, participatory hearing or special application decisions, and refers to people by initials. The exception is the monetary orders database, which does contain the file number, both parties' names and the rental address, and administrative penalty decisions, where respondent names survive redaction.

So a park's dispute history is not publicly verifiable in any complete way. Cover it contractually instead. I want a seller warranty on RTB proceedings, orders and outstanding applications, plus the seller's own file.

The local policy layer that can reprice the land

Provincial rules are the floor. Local government builds on top, and the additions are not small.

West Kelowna adopted its manufactured home park redevelopment policy, policy number 0008, on September 16, 2025 by council resolution C210/25, replacing a 2008 policy. It applies to every zoning bylaw amendment application that would redevelop a park, and it sits on top of anything the province requires. The application needs a tenant relocation plan and a statement of occupancy, a designated tenant relocation coordinator, a tenant information meeting before first reading, and one-on-one tenant meetings.

The compensation detail is where a pro forma breaks. Relocation assistance means at least three alternative accommodation options, prioritizing the same general area, at rent generally not exceeding the greater of 10% above CMHC average market rent for West Kelowna or 10% above the rent currently paid. Renting tenants get moving expenses of $1,000 for one bedroom or less, $1,250 for two, and $1,500 for three or more, indexed annually to CPI, plus rent-based compensation running from three months of rent under five years of tenure up to six months at 20 years or more. Homeowning tenants get a professional appraisal of the home and its relocation feasibility, and the applicant is responsible for relocating the home within the Okanagan at the tenant's written request or disposing of it. Where the home is disposed of, compensation is the greater of appraised value, BC Assessment value, or the amount the MHPTA requires. Where it is relocated, it is the MHPTA amount.

Do not stack that on top of the provincial number, which is the mistake I see in pro formas. The policy folds the MHPTA compensation into its own test rather than adding to it: the provincial amount is one of the three figures in the greater-of test for a home being disposed of, and it is the whole measure for a home being relocated. Renter compensation likewise includes what tenancy legislation already requires. The policy raises your floor in most cases. It does not simply double it.

Regional districts regulate too. The Regional District of Okanagan-Similkameen requires a manufactured home park permit under Bylaw No. 2597, 2012, which applies in Electoral Areas A, C, D, E, F, H and I rather than district wide, and covers spacing, water supply, sewage treatment and disposal, roadways and more. Existing parks are not compelled to upgrade, but any expansion must meet the bylaw. The Regional District of Nanaimo has a similar bylaw for Electoral Area F, Bylaw No. 1738, 2016. The enabling power for both is section 298(1)(j) of the Local Government Act, which lets a regional district regulate the construction and layout of manufactured home parks.

So a seller's redevelopment story is only worth what the local policy allows. Read the policy before you price the land, not after the rezoning application goes in.

If you only keep four items

Keep these: the operating permit that does not transfer, the section 9 sewage certification letter, a registry search on every home in the park, and the local redevelopment policy. The rest of this list protects you from surprises. Those four are the ones I have watched move a price after the offer was already in.

I am a broker, not a lawyer or an accountant, and this is a summary rather than legal or tax advice. Section numbers here reflect the consolidations current in August 2026. Get counsel on your specific deal.

If you want to know which of these apply to a particular park before you spend money on reports, send me the address. I will tell you what I would check first.

Logan Crowder
Logan Crowder
Mobile Home Park Specialist · BC
Logan focuses exclusively on mobile home park transactions across British Columbia at CDW & Associates · Remax Commercial Advantage. He holds a Diploma in Urban Land Economics from UBC Sauder and is a CCIM candidate.
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