We don't internally classify non-dwelling secured HI loans as HI, therefore we don't report them. My advice: i'd attack this problem the opposite way from what it sounds like you're doing. First, determine internally whether or not you classify such loans as HI (in other words, if you wanted to pull a list of all your home improvement loans, through your core system, etc.....could you fairly easily do so? Or do you group or color code such paper files in a way that you could pull out the HI ones easily?) If the answer is yes, then you have to report them. If the answer is no: i definitely wouldn't go out of my way to start classifying them so that i would have to report. Hope that helps.
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I'm fixin' to fix that.