Oregon Manufactured Home Park Closure Notification Requirements — Landlord Compliance Guide (2026)

What Is a Manufactured Home Park Closure Under Oregon Law?

A manufactured home park closure under ORS 90.645 is defined as the discontinuance of a park's operation in a manner that would displace all or substantially all manufactured home park tenants. This includes:

• Permanent cessation of park operations
• Conversion of the park to non-residential use
• Conversion to different residential use (apartments, condominiums, etc.)
• Sale of the property when the new owner does not intend to continue park operations
• Any circumstance where residents cannot continue occupying their manufactured homes in the same location

Oregon's statute does not distinguish between voluntary closures (owner-initiated) and involuntary closures (foreclosure, bankruptcy). The notice requirement applies regardless of why the park will close. This is a critical compliance point — even if you're inheriting a park through foreclosure or facing financial difficulty, the 24-month notice obligation still exists.

The law applies to all manufactured home parks in Oregon with any residents occupying manufactured homes on the property. Parks with a single mobile home are covered. Parks with dozens of units are covered. The size of the park does not reduce compliance obligations.

The 24-Month Notice Requirement: Statutory Framework

ORS 90.645(1) states: "No park owner may discontinue the operation of a manufactured home park in a manner that will result in displacement of park tenants unless the park owner provides notice to all park tenants not less than 24 months before the anticipated date of discontinuance."

This is not a suggestion. It is a mandatory statutory duty. Courts have consistently held that the 24-month notice is a precondition to lawful closure. Without compliance, residents have grounds to sue and prevent the closure.

What Constitutes Proper Notice Under ORS 90.645?

Written notice must be delivered to all park tenants and must include the following information:

• The anticipated date of discontinuance (the last date of park operations)
• A statement that the park will close and residents must vacate
• Information about relocation resources available to tenants
• Information about financial assistance programs (state or local)
• The park owner's relocation plan showing efforts to assist residents in relocating
• Information about tenant rights under Oregon law during the notice period

Notice must be provided in writing. Email, text message, or verbal notice does not satisfy the statute. The standard is certified mail or personal delivery with proof of receipt. This creates a clear compliance record and protects the park owner from claims that notice was not given.

Notice should be dated and should identify all park residents receiving it. If residents change during the 24-month period, new residents must also receive the closure notice within a reasonable time after moving in.

The 24-Month Timeline: When Does It Start?

The notice period begins on the date the park owner delivers notice to all residents. It ends 24 months later on the "anticipated date of discontinuance" stated in the notice.

Example: If notice is given on January 15, 2027, and the closure date stated in the notice is January 15, 2029, the park must remain operational through that date. Residents have until January 15, 2029 to vacate.

The park owner cannot shorten this timeline. If circumstances change and the closure will occur earlier than originally stated, the park owner must provide additional notice to all residents of the new closure date, with at least 24 months from the new notice date.

Mandatory Contents of the Closure Notice

Relocation Assistance Information

Under ORS 90.645(2), the notice must include information about relocation resources. This is not optional language — the statute specifically mandates it. The notice must identify:

• Local and state relocation assistance programs
• Financial assistance available to help with moving costs
• Resources for finding alternative housing
• Any financial assistance the park owner will provide directly
• Contact information for local housing authorities or nonprofits offering relocation support

Parks cannot simply state "you have 24 months to leave." The notice must affirmatively provide information about where residents can find help. Oregon's Department of Consumer and Business Services (DCBS) has published guidance indicating that the notice should include specific agency names, phone numbers, and websites.

The Park Owner's Relocation Plan

The notice must describe the park owner's plan to assist residents in relocating. This plan should include:

• Whether the park owner will offer financial assistance beyond what is legally required
• Whether the park owner will help residents identify relocation properties
• Whether the park owner will negotiate with other parks or housing providers on residents' behalf
• The timeline for residents to vacate during the 24-month period
• Any other specific assistance the park owner commits to providing

The plan does not need to solve the displacement crisis for residents, but it must demonstrate a reasonable good-faith effort to assist. A notice that merely states "we are closing in 24 months, good luck" will not meet the statutory requirement.

Tenant Rights During the Notice Period

The notice must inform residents of their rights during the 24-month notice period. Specifically:

• Residents may not have their leases terminated for non-cause reasons during the 24-month period (ORS 90.645(5))
• Residents cannot be subjected to rent increases except for utilities or services-related cost increases
• Residents have the right to file complaints with the Oregon Attorney General or local authorities
• Residents may have legal remedies if the park owner fails to comply with ORS 90.645

Including this information in the closure notice protects both the park owner and residents by establishing clear expectations from the outset.

Rent Increases and Lease Terminations During the 24-Month Notice Period

The Freeze on Non-Cause Terminations

ORS 90.645(5) explicitly prohibits park owners from terminating tenancies for non-cause reasons during the 24-month notice period. "Non-cause" means:

• Termination without citing a specific lease violation
• Termination simply because the park owner wants the unit vacant
• Termination based on the owner's decision to close the park
• Termination based on the sale or transfer of the park property

Park owners can still terminate leases for cause during this period, such as:

• Non-payment of rent (with proper notice and opportunity to cure under ORS 90.360)
• Material breach of the lease (such as operating an illegal business or causing property damage)
• Violation of park rules adopted in compliance with Oregon law
• Violation of local codes or state health and safety regulations

The distinction between cause and non-cause termination is critical. Park owners who attempt to empty the park before the 24-month period ends by issuing non-cause terminations will face liability. Residents can sue for wrongful termination and recover damages plus attorney fees under ORS 90.750.

Rent Increase Restrictions

During the 24-month notice period, rent increases are restricted but not completely prohibited. Under ORS 90.645, rent may be increased only to cover:

• Increases in utilities or services actually provided to the resident
• Increases in property taxes directly attributable to the property (rare in mobile home parks)
• Increases required by lenders or government agencies

Discretionary rent increases — increases made simply because market conditions allow — are prohibited during the closure notice period. This protects residents from being priced out of their homes before they have time to relocate.

Example: If a park owner typically raises rent 3-5% annually based on CPI (cost of price index), those discretionary increases cannot occur during the 24-month notice period. However, if the park's water utility bill increases 10%, a proportional water fee increase is permitted.

Enforcement and Penalties for Non-Compliance

Private Right of Action Under ORS 90.750

Residents harmed by a park owner's violation of ORS 90.645 can sue directly. Under ORS 90.750(1), a tenant may recover:

• Actual damages (out-of-pocket losses, including relocation costs, moving expenses, hotel stays, etc.)
• Up to $4,000 in civil penalties per violation
• Attorney fees and court costs (the prevailing tenant's attorney is paid by the park owner)
• In some cases, punitive damages if the violation was willful

These are substantial penalties. A park with 30 residents who were not properly notified could face $120,000 in civil penalties alone, plus actual damages for each resident's relocation costs plus attorney fees. Oregon courts have awarded damages exceeding $50,000 in manufactured home park closure disputes.

Oregon Attorney General Enforcement

Violations of ORS 90.645 can be reported to the Oregon Attorney General's Consumer Protection Section. The Attorney General may:

• Investigate complaints of non-compliance
• Issue cease-and-desist orders requiring compliance
• Initiate civil actions on behalf of residents
• Seek injunctive relief preventing closure until notice is properly given
• Seek penalties and damages on behalf of the state

The Attorney General's involvement is not optional — it is triggered by resident complaints. Park owners cannot settle disputes privately and escape state enforcement action.

Local Code Enforcement

Some Oregon municipalities have local tenant protection ordinances that parallel or exceed state requirements. Portland, Eugene, and other larger cities have local housing authorities that monitor manufactured home park closures. Violations can result in local enforcement actions in addition to state-level remedies.

Injunctive Relief and Closure Prevention

If a park owner attempts to close without proper notice or in violation of ORS 90.645, residents can seek a court order (injunction) preventing the closure until statutory requirements are met. Courts have broad equitable power to halt closures and require compliance with the 24-month notice period.

This means that even if a park owner has already begun closure procedures or given residents short notice, a court can order the park to remain open and operational until the proper 24-month period has elapsed.

Step-by-Step Compliance Checklist for Park Closure

If you own a manufactured home park in Oregon and have decided to close, follow this checklist to ensure full compliance with ORS 90.645:

Step	Action	Deadline
1	Consult with an Oregon real estate attorney to review ORS 90.645 and local requirements	Before taking any action
2	Identify all current residents in the park and verify their contact information	Before drafting notice
3	Research and compile a list of relocation assistance resources (local, state, and nonprofit)	Before drafting notice
4	Develop a park owner relocation assistance plan (financial, logistical, etc.)	Before drafting notice
5	Draft the closure notice using the required statutory language and all mandatory contents	Before delivering notice
6	Have the attorney review the notice for compliance with ORS 90.645(2)	Before delivering notice
7	Deliver notice to all residents via certified mail or personal service with signed receipt	Day 1 of 24-month period
8	Document all deliveries and keep proof of receipt (certified mail receipts, signed acknowledgments)	Immediately after delivery
9	Freeze rent increases (except utilities/services cost pass-through) for 24-month period	From notice date forward
10	Prohibit non-cause terminations for 24 months; continue cause-based enforcement only	From notice date through closure date
11	Notify new residents who move in during the 24-month period of park closure	Within 5 days of move-in
12	Maintain park in safe, habitable condition (do not defer maintenance during notice period)	24-month period
13	On closure date, provide final rent accounting and return security deposits per ORS 90.300	Closure date + 30 days

Park Maintenance Obligations During the 24-Month Notice Period

Oregon law does not permit park owners to defer maintenance or reduce services during the 24-month notice period. The park remains subject to all habitability requirements under ORS 90.320.

This means:

• Water, sewer, and electrical systems must be maintained in working order
• Roads and common areas must be kept safe and accessible
• Pest control and trash removal must continue
• Parks must continue to comply with local health codes and building standards
• The park owner cannot cut corners to reduce expenses during the final 24 months

Residents who experience habitability violations during the notice period can pursue remedies independently of the closure. They can file complaints with local code enforcement, sue for damages, or assert an "implied warranty of habitability" defense if the park owner later attempts to evict them for non-payment.

If you're contemplating closure, budget for full park maintenance through the closure date. Cutting corners will only increase your legal exposure.

Special Situations: Involuntary Closures and Foreclosure

Foreclosure and Bank-Ordered Closure

If your manufactured home park is in foreclosure and the lender intends to close the park after acquiring the property, the 24-month notice requirement still applies. The current owner (during foreclosure) must provide the notice, or the new owner (after foreclosure) must provide it.

If notice is not given before foreclosure completes, the new owner inherits the obligation. The 24-month clock does not start until proper notice is delivered to all residents. A new owner cannot circumvent the requirement by claiming they were unaware of the prior owner's closure plans.

If you are facing foreclosure, consult with an attorney immediately. Providing proper closure notice may actually reduce liability and demonstrate good faith to residents and the court.

Sale of the Park with Continued Operations

If you sell the park to a new owner who intends to continue operating it as a manufactured home park, ORS 90.645 does not apply. No closure notice is required because the park is not closing.

However, if the sale is contingent on closure or the new owner plans to close the park after purchase, the 24-month notice must be provided before or immediately after the sale. Waiting to announce closure after the sale closes will not reset the 24-month clock — residents will argue the notice was improperly delayed.

Frequently Asked Questions

Q: Can I give notice that the park will close in less than 24 months if I compensate residents financially?

A: No. ORS 90.645 does not allow abbreviated notice periods regardless of financial compensation. The 24-month notice requirement is mandatory and cannot be waived by agreement or payment. However, offering relocation assistance (moving costs, deposits, etc.) will help you meet the statutory relocation assistance requirement and may reduce tenant litigation risk.

Q: What if some residents do not receive the closure notice? Do I need to re-notice everyone?

A: If any resident does not receive proper notice, the closure date cannot pass until that resident has received the notice and had 24 months from receipt. This can significantly complicate closures. Use certified mail with return receipt to document delivery to every resident. If a resident moves out without leaving a forwarding address, keep detailed records of your good-faith attempts to locate them. Consult your attorney if notice cannot be delivered to a particular resident.

Q: Can I prohibit new residents from moving in during the 24-month notice period?

A: Legally, you cannot prevent someone from moving in based solely on the pending closure. However, you can require new residents to sign an acknowledgment that they received closure notice and understand the park will close on the specified date. Some park owners negotiate discounted rental rates for the notice period to incentivize shorter stays. Any restrictions on new residents should be discussed with your attorney to ensure compliance with fair housing laws.

Q: Can residents withhold rent or reduce payments during the notice period?

A: No. Residents remain obligated to pay full rent through the closure date. However, if the park owner fails to maintain habitability (water outage, code violations, etc.), residents may have the right to repair-and-deduct or abate rent under Oregon law. Do not give residents grounds to withhold rent by deferring maintenance.

Q: What happens if I sell the park during the 24-month notice period?

A: The new owner steps into your shoes and must comply with the closure timeline you established. The 24-month period does not reset. Residents will hold the new owner accountable for the closure date specified in the original notice. Your sale documents should disclose the pending closure and the outstanding notice obligations to the new owner. Failure to do so may create fraud or misrepresentation liability.

Resources for Oregon Landlords Managing Park Closures

• Oregon Department of Consumer and Business Services (DCBS): Publishes guidance on manufactured home park closures and landlord obligations. Visit oregon.gov/dcbs for resources.
• Oregon Attorney General Consumer Protection Section: Handles complaints about park closure violations. File complaints at oregonattorneygeneral.gov.
• Local Housing Authorities: City and county housing authorities in your area can direct residents to relocation assistance programs and may monitor park closures.
• Oregon Manufactured Housing Association: Industry resource for park owners (if member). May provide guidance and attorney referrals for closure planning.
• Legal Aid Organizations: Services like Legal Aid Services of Oregon provide tenant representation in closure disputes. Understanding their arguments helps park owners structure compliant closures.

If you manage a portfolio of manufactured home parks or handle frequent resident transitions, a compliance platform can help track resident status, document delivery of notices, and ensure rent restrictions are maintained during notice periods. LeaseBase's compliance tools can streamline documentation of closure notice delivery and maintain records of all residents in the park at the time of notice — critical evidence if litigation arises.

Conclusion: The Cost of Non-Compliance vs. Proper Planning

ORS 90.645 is not ambiguous. It requires 24 months' notice, specific content, and statutory protections for residents during that period. The penalties for non-compliance are substantial: up to $4,000 per resident in civil penalties, plus actual damages, plus attorney fees.

A park with 40 residents that fails to provide proper notice faces potential exposure of $160,000 in penalties alone. If residents incur $10,000 each in unexpected relocation costs, total damages could exceed $560,000, plus attorney fees.

The cost of compliance — providing proper notice, maintaining the park for 24 months, and assisting with relocation — is far lower than the cost of defending litigation brought by 30-50 residents plus the state Attorney General.

If you are considering closing a manufactured home park in Oregon, consult with an Oregon real estate attorney before taking any action. The attorney can review your specific situation, draft a compliant notice, and advise on relocation assistance strategies. The investment in proper planning will protect you from years of litigation and six-figure damage awards.

Disclaimer: This article is for informational purposes only and does not constitute legal advice. Consult a qualified Oregon attorney for guidance specific to your situation. Manufactured home park closure law is complex and varies by local jurisdiction. Professional legal review is essential before providing closure notice.