So far, the recomendation is for non-dwelling consumer loans are not to be classified as home improvements so dont report.
It's totally up to management at your bank as to whether you report these loans or not. Most banks don't report for reasons stated above. I have heard, though, some bank's want the added support of those loans on the LAR for whatever reason......not really sure what that reason might be. But reporting is totally optional. Just remember, if you "classify" you MUST report. If you don't want to report, just make sure there is no way to pull a list of these from your data base or hard copy files. Pay attention to purpose codes, if you use those. If you use a code for "
home improvements" then your loans are classified and you must report the loans.