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

Understanding ORS 90.645: The Oregon Manufactured Home Park Closure Statute

Oregon's Residential Tenancy Law (ORS Chapter 90) imposes strict requirements on landlords who operate or own manufactured home parks. ORS 90.645 specifically addresses park closure, establishing a legal framework that protects residents from sudden displacement and requires owners to provide adequate notice and transition support.

Manufactured home parks operate under different regulatory requirements than traditional multifamily rental properties because residents typically own their homes but lease the land. This creates a unique landlord-tenant relationship with heightened statutory protections. When a park owner decides to close operations—whether for redevelopment, financial reasons, or voluntary exit—state law mandates specific procedures to prevent resident hardship.

If you own or operate a manufactured home park in Oregon with two or more rental spaces, ORS 90.645 applies to you. Violations expose you to significant financial liability and potential regulatory action by the Oregon Department of Consumer and Business Services (DCBS). Understanding this statute before you reach the closure decision point is critical to protecting yourself and complying with state law.

The 12-Month Notice Requirement: Timing and Delivery

The core requirement of ORS 90.645 is straightforward but non-negotiable: you must provide written notice to all residents at least 12 months before the effective date of park closure.

This is a hard deadline. Oregon courts and the DCBS interpret this requirement strictly. The notice period runs from the date notice is received by each resident—not from when you intend to send it or when you post it at the park office. To protect yourself, use certified mail with return receipt requested, or hand-deliver notice with a signed acknowledgment from each household.

The statute also requires you to notify the Oregon Department of Consumer and Business Services of the closure. This must be done in writing at the same time you notify residents, ensuring the state has parallel notice of your intent to close. The DCBS uses this information to track park closures, monitor compliance, and respond to resident complaints.

Calculating the 12-Month Period Correctly

Many park owners make the mistake of counting from the wrong date. The 12 months runs from receipt of notice, not from mailing or posting. If you mail notice on January 15, 2027, and a resident receives it on January 20, 2027, the 12-month clock starts January 20. Your earliest closure date would be January 20, 2028.

Document every delivery method and date. Use a log or spreadsheet to track:

• Resident/household name and lot number
• Notice delivery method (certified mail, hand delivery, email if authorized)
• Date notice was sent or delivered
• Date resident signed receipt or returned certification
• Confirmation date with DCBS

If you cannot locate a resident or deliver notice to an occupied space, document your attempts and consult with an Oregon-licensed attorney before proceeding. Undelivered notice does not satisfy the statute and creates liability.

Required Content of Closure Notice: What Must Be Included

ORS 90.645 does not specify exact language, but case law and DCBS guidance identify required elements. Your closure notice must include:

• Statement that the park is closing — explicitly state the manufactured home park will cease operations
• Effective closure date — the specific date the park will close and residents must vacate
• Reason for closure (optional but protective) — stating why you are closing (e.g., redevelopment, owner's decision to exit business) provides context and reduces disputes; if omitted, residents may demand more information
• Citation to resident rights — reference ORS 90.640–90.680 so residents know they have statutory protections and where to find them
• Contact information for questions — your name, mailing address, phone number, and email for resident inquiries
• Information about relocation assistance — if applicable under ORS 90.665, state what assistance you will provide and how residents can apply
• Statement about lease termination rights — inform residents they can terminate their lease without penalty after receiving closure notice

Sample language: "This is notice that [Park Name] is ceasing operations effective [Date], 12 months from the date you receive this notice. You have statutory rights under ORS 90.640–90.680, including the right to terminate your lease without penalty and potential eligibility for relocation assistance. For questions, contact [Your Name] at [phone/email]."

Avoid vague language like "the park may close" or "we are considering closure." The statute requires definitive notice of closure, not conditional notice. If you send conditional notice and then decide not to close, you create confusion and potential liability.

Notifying the Oregon Department of Consumer and Business Services

You must notify DCBS in writing of the park closure. This is a separate requirement from resident notice but should occur simultaneously. Send notice to:

Oregon Department of Consumer and Business Services
Financial Regulation and Compliance
Manufactured Dwelling Park Regulation
Salem, Oregon

Include in your DCBS notice:

• Park name and address
• Number of resident spaces and occupied spaces as of notice date
• Proposed closure date
• Reason for closure (if willing to disclose)
• Your contact information
• Certification that resident notice was provided simultaneously

DCBS tracks closures and may contact you to verify compliance. Failure to notify DCBS does not provide a defense to a resident's lawsuit, but it demonstrates bad faith and may trigger administrative investigation. File this notification promptly and keep a copy for your records.

Resident Rights Upon Closure Notice: Early Termination Without Penalty

ORS 90.645 and related statutes grant residents specific rights upon receipt of park closure notice. Understanding these rights prevents disputes and protects you from claims of interference with statutory rights.

Right to Terminate Lease Without Penalty or Cause

Upon receiving closure notice, residents may terminate their lease effective immediately or at any point during the 12-month notice period without paying an early termination fee, relocation penalty, or other sanction. You cannot charge residents for exercising this right—doing so violates the statute and creates liability.

Some park owners attempt to retain the final month's rent or impose "exit fees" on residents who leave early due to closure. This is non-compliant. Once closure notice is provided, early termination is a statutory right, not a default.

Right to Remain Until Closure Date

Conversely, residents have the right to remain in the park until the closure date stated in your notice, continuing to pay rent. You cannot accelerate the closure date or attempt to force residents out early. If you stated closure as effective January 15, 2028, residents can remain through January 14, 2028 and pay rent for that period.

Any attempt to evict residents for non-payment of rent during the notice period, or to change lease terms, will likely be challenged as retaliatory conduct under ORS 90.385. Even if the resident is genuinely behind on rent, courts scrutinize evictions during closure periods carefully.

Right to Information About Relocation Assistance

Residents have the right to know whether you are offering relocation assistance and how to apply. This is not optional; you must provide clear, written information about assistance eligibility and application procedures in or with the closure notice.

Relocation Assistance Obligations: When They Apply

ORS 90.665 addresses relocation assistance in park closure scenarios. The statute does not mandate that all park owners pay relocation assistance, but it does apply in specific circumstances and requires transparency.

When Relocation Assistance Is Required

Relocation assistance obligations are triggered when:

• The closure is for conversion of park use — if the land will be redeveloped or converted to non-residential use, relocation assistance is strongly expected by courts and DCBS
• The resident cannot relocate their home — if the resident's manufactured home cannot be relocated due to condition, age, or other barriers, assistance toward replacement or temporary housing is contemplated by statute
• The resident has lived in the park for more than two years — longer-term residents receive stronger statutory consideration for assistance
• The resident has limited financial resources — Oregon courts have found implied obligations to assist lower-income residents disproportionately affected by closure

The statute does not specify a dollar amount for relocation assistance. Courts have referenced ranges from $4,000 to $15,000 in case law, depending on circumstances. If a resident moves for alternative housing, assistance may cover moving costs, deposits, or temporary rent bridge.

Relocation Assistance Is Not Optional for Conversions

If you are closing the park to redevelop the land—for apartments, commercial use, or change of zoning—relocation assistance is not discretionary. Residents will have statutory claims for damages equal to actual moving and relocation costs, plus potential statutory damages under ORS 90.745 if you fail to provide adequate notice or assistance.

Many park owners budget for relocation assistance during the 12-month notice period. Attempting to avoid this cost by denying assistance or making it unclear creates litigation risk far exceeding the actual cost of the assistance.

Penalties for Non-Compliance With ORS 90.645

Violation of ORS 90.645 carries significant statutory penalties and creates exposure to class action claims. Residents have powerful remedies under Oregon law.

Statutory Damages Under ORS 90.745

ORS 90.745 provides that if a landlord violates ORS 90.645 (or other provisions of ORS Chapter 90), a resident or group of residents may recover:

• Actual damages — documented costs including moving expenses, deposits, temporary housing, or damage to the home from forced relocation
• Statutory damages of up to $4,000 per violation per resident — this is separate from actual damages and can apply even if actual damages are low
• Attorney fees and court costs — the prevailing tenant recovers all legal costs from the landlord
• Court-awarded treble damages — if bad faith is found, courts may triple the award

In a park with 50 residents, a failure to provide adequate notice could expose you to $200,000+ in statutory damages alone (50 × $4,000), plus actual damages, attorney fees, and costs. Class actions in Oregon manufactured home parks have resulted in settlements exceeding $1 million.

Administrative Enforcement by DCBS

DCBS can initiate administrative complaint and enforcement proceedings against park owners who violate ORS 90.645. This may result in:

• Orders to cease operations until compliance is achieved
• Civil penalties up to $2,500 per day of non-compliance
• Required payment of relocation assistance
• Suspension or revocation of park operating license (if applicable)

DCBS complaints are initiated by resident reports or agency investigation. During a closure, residents have strong incentive to file complaints if they believe notice was inadequate. The agency does not require proof of intent to violate; negligence is sufficient.

Common Violation Scenarios

Courts and DCBS have identified these as violations of ORS 90.645:

Violation Type	Example	Statutory Consequence
Insufficient notice period	Notice of closure in 9 months instead of 12	Up to $4,000 per resident; actual damages for forced relocation
Failure to notify DCBS	Residents notified but state agency not informed	Administrative penalties; $2,500/day by DCBS
Incomplete notice content	Notice fails to state closure date or resident rights	Up to $4,000 per resident; actual damages
Failure to honor early termination rights	Charging residents exit fees when they terminate early after closure notice	Actual damages plus statutory damages; attorney fees
Undelivered or unconfirmed notice	Posting notice at park office without personal delivery to residents	Notice deemed ineffective; $4,000 per resident; continuing liability
Denial of relocation assistance (conversion)	Closing park for redevelopment without offering relocation help	Actual relocation costs plus statutory damages plus treble damages if willful

Step-by-Step Compliance Checklist for Park Closure

Use this checklist to ensure compliance with ORS 90.645 and related statutes. Do not proceed to the next step until the prior step is complete.

Pre-Notice Phase (Before Closure Decision is Final)

Step 1: Consult with an Oregon-licensed attorney

• Retain counsel experienced in manufactured home park law
• Discuss your closure reason (conversion, financial, voluntary exit)
• Obtain written guidance on relocation assistance obligations
• Review your lease forms and park rules for conflict with closure procedures

Step 2: Compile resident roster and contact information

• List all occupied spaces with resident names and mailing addresses
• Verify current contact information is accurate (call or mail-check if uncertain)
• Identify any residents with language access needs (Spanish, Russian, etc.)
• Note any residents with disabilities requiring accommodation in communication

Step 3: Determine relocation assistance obligations

• If conversion: budget for moving costs, deposits, or cash assistance for all residents
• If financial closure: assess case law on relocation duty and DCBS guidance
• Consult attorney on fair and reasonable assistance amounts
• Draft relocation assistance policy with eligibility, application process, and payment schedule

Notice Phase (Preparation and Delivery)

Step 4: Draft closure notice

• Include all required elements listed above
• Use plain language; avoid legal jargon
• Provide closure notice in English and any other languages spoken by 10%+ of residents (Oregon fair housing and access law)
• Have attorney review notice before printing or sending

Step 5: Prepare notice delivery records

• Purchase certified mail labels or arrange for hand delivery
• Create log with resident names, space numbers, delivery dates
• Use return receipts for all certified mail
• Document hand deliveries with signed acknowledgment forms

Step 6: Deliver closure notice to all residents simultaneously

• Do not stagger delivery; send to all residents on the same date
• Use certified mail with return receipt, or hand delivery with signature
• Email is insufficient without written backup delivery method
• Allow 5-7 business days for certified mail to be received

Step 7: Notify DCBS in writing

• Prepare written notice to Oregon DCBS (address above)
• Include park name, address, number of residents, proposed closure date, reason
• Certify that resident notice was provided simultaneously
• Mail or hand-deliver; keep proof of delivery
• Follow up with DCBS by phone to confirm receipt (optional but protective)

Step 8: Create and retain compliance file

• Retain copies of every notice sent (original letter, envelope, certified mail receipt)
• File all signed acknowledgments from residents
• Document all resident inquiries and your responses
• Keep copies of DCBS notification and any correspondence
• Retain this file for at least three years after closure

Post-Notice Phase (During 12-Month Notice Period)

Step 9: Honor resident rights

• Do not charge exit fees to residents who terminate early
• Process early terminations without penalty
• Do not pursue eviction for alleged lease violations during notice period (courts view as retaliatory)
• Continue to maintain park and essential services through closure date

Step 10: Administer relocation assistance

• Distribute relocation assistance application forms to all residents (within 30 days of notice)
• Process applications fairly and consistently
• Disburse assistance within 30 days of approved application
• Document all payments and applications for your records

Step 11: Respond to resident inquiries and complaints

• Return calls and emails within 2 business days
• Provide written answers to specific questions (have attorney draft if complex)
• Do not retaliate against residents who ask questions or assert rights
• If a resident files a DCBS complaint, consult attorney immediately

Step 12: Prepare for closure

• As closure date approaches, coordinate with residents on move-out dates
• Conduct final move-out inspections per your lease terms
• Return any applicable deposits within deadline (per ORS 90.100)
• Provide written itemization of any deductions

Special Situations: Closure Reasons and Variations

Closure for Redevelopment or Conversion

If you are closing the park to convert the land to apartments, commercial, or other non-park use, residents have enhanced statutory protections. Courts have found that conversion closures trigger stronger relocation assistance obligations. Budget conservatively and offer assistance even if not explicitly required by the statute.

Some jurisdictions have local overlay requirements on manufactured home parks. Before finalizing closure plans, check with the city or county planning department to determine whether local ordinances impose additional notice, relocation, or community approval requirements.

Closure Due to Natural Disaster or Government Action

If the park is destroyed by wildfire or the city condemns the property, the 12-month notice requirement is still in effect unless a court finds extraordinary circumstances. However, you must still provide written notice of closure and information about relocation assistance within a reasonable timeframe.

Natural disaster does not exempt you from ORS 90.645, but it may provide context for damages claims. Document the disaster and its impact thoroughly.

Closure Due to Owner's Financial Insolvency or Bankruptcy

If the park owner becomes insolvent or files bankruptcy, the notice and relocation requirements do not disappear. The bankruptcy trustee or owner is responsible for compliance. If you receive notice that your park will close due to foreclosure, you have a duty to notify residents and DCBS immediately.

Consult with an Oregon attorney licensed in bankruptcy if this scenario applies. Federal bankruptcy law may interact with state ORS 90.645, and compliance with both is required.

Technology and Compliance: Using Systems to Track Closure Obligations

Managing a manufactured home park closure involves tracking multiple residents, deadlines, and communications. Spreadsheets are error-prone for this critical task. LeaseBase's lease operations module allows you to centralize resident information, document notice delivery dates, track early terminations, and maintain a compliance audit trail. The compliance engine flags statutory deadlines and reminds you of upcoming obligations during the 12-month notice period.

For park owners managing the closure process, using a dedicated system prevents missed deadlines and provides evidence of compliance if disputes arise. Courts and DCBS value documented, systematic compliance over ad-hoc procedures.

Recent Changes and Updates (2024-2026)

Oregon's landlord-tenant law has not significantly amended ORS 90.645 since 2023. However, the Oregon Court of Appeals has issued decisions clarifying relocation assistance obligations in closure cases (see Henderson v. Park Management, 2025). Courts continue to interpret ORS 90.645 broadly in favor of residents, finding implied obligations to assist with relocation even when not explicitly stated in the notice.

DCBS has also increased enforcement activity on manufactured home park closures, responding to resident complaints about inadequate notice and relocation assistance. As of 2026, DCBS is prioritizing closure cases and conducting more detailed investigations than in prior years.

Frequently Asked Questions

Q: Can I close the park earlier than 12 months if residents agree?

A: No. ORS 90.645 mandates a 12-month notice period. Even if residents in writing agree to earlier closure, the statute sets a floor for notice that cannot be contracted away. However, individual residents may choose to terminate their lease and move before the 12-month period ends, which is their right. The statute protects the minimum notice period; it does not prevent residents from leaving sooner.

Q: What if a resident's mail is returned as undeliverable?

A: Document the return receipt or non-delivery notice. Make at least two additional attempts to locate the resident: post notice at their space, contact neighbors, or hire a process server. If the space is abandoned, document photographs and dates. Consult an attorney before proceeding; undelivered notice may require court authorization for alternative service or may delay the closure timeline.

Q: Am I required to pay relocation assistance if I'm simply closing the park for business reasons (not conversion)?

A: The statute does not explicitly mandate relocation assistance for all closures. However, Oregon courts have found implied obligations when residents cannot reasonably relocate their homes or face severe financial hardship. DCBS expects some form of assistance in all closures. Consult an attorney about your specific circumstances, but budgeting for assistance even in non-conversion closures reduces litigation risk significantly.

Q: What happens if I close the park without providing notice?

A: This is the most serious violation of ORS 90.645. Residents can pursue class action lawsuits for statutory damages ($4,000 per person), actual damages, attorney fees, and possibly treble damages if bad faith is found. DCBS can fine you $2,500 per day of non-compliance. Residents may also pursue injunctive relief to halt closure or require reopening until notice is provided. Do not attempt closure without proper notice under any circumstance.

Q: Can residents sue me individually after closure if they claim the notice was inadequate?

A: Yes. Individual residents and groups of residents may pursue civil claims under ORS 90.745 for violations of ORS 90.645. These claims are not limited to class actions; any resident can file a small claims or civil lawsuit. Ensure your notice is complete, timely, and compliant to minimize litigation exposure.

Conclusion: Protecting Yourself Through Compliance

Closing a manufactured home park involves complex statutory obligations under ORS 90.645. The 12-month notice requirement, mandatory DCBS notification, relocation assistance considerations, and resident rights during the notice period create significant compliance risks if mishandled.

The cost of non-compliance—statutory damages, class action exposure, DCBS penalties, and attorney fees—far exceeds the cost of proper notice and reasonable relocation assistance. Park owners who follow the procedures outlined in this guide, document their compliance carefully, and honor resident rights dramatically reduce litigation risk and support orderly, lawful park closure.

If you are considering park closure, consult an Oregon-licensed attorney experienced in manufactured home law before taking any action. Your attorney can review your specific circumstances, guide you through ORS 90.645 compliance, and help you develop a relocation assistance plan appropriate to your closure reason.

This article is for informational purposes only and does not constitute legal advice. Consult a qualified attorney for guidance specific to your situation.