In Livingston v. Vanguard F S B, 386 Pa. Super. 496, 563 A.2d 175 (1989), the Superior Court of Pennsylvania considered whether the Pennsylvania statute that prohibited prepayment fees on home loans would apply or be preempted if the document at issue was a mobile home installment contract. Livingston, 386 Pa. Super. at 499, 563 A.2d at 176.
The court held that loans referred to in federal regulations pertaining to home loans did not specifically include mobile home sales or lending. Id., 386 Pa. Super. at 504, 563 A.2d at 179.
Therefore, the court determined the Pennsylvania prepayment fee statute was not preempted by federal law when applied to an installment contract for a mobile home. Id., 386 Pa. Super. at 505, 563 A.2d 175, 180.