Home Sale Workaround Idea - Increased Lot Rent

I came across a park owner during this years SECO conference who has a workaround for Dodd Frank/SAFE Act MLO requirements for selling homes in his park. For example if he sells a $10k home, he would take $4k as the Bill of Sale payment for the home. And if the normal lot rent is $400, he would instead charge the home buyer $600 per month in lot rent ($200 extra) for 30 months in order to recover the remaining $6k for the home.

Would some consider this a disguised mortgage? I suppose much of this would come down to how you contractualize the agreement. If you sell the home for cash in a Bill of Sale, and you have a completely independent lot rent agreement, it seems this would create enough separation to avoid truly having a disguised mortgage. This arrangement would also provide a nice bump to your capitalized lot rent and hypothetically increase the value of the park. Interested to get the forum’s thoughts on this tactic.