I agree with you. The GIR guide says you can use "NA" for multi-family dwellings and for properties located outside an mSA or inside an MSA in which you do not have a home or branch office. I don't read where it says to use NA for non-dwelling secured HI loans.
You are required to report the location of the property being improved, so it makes sense to report the owner-occupancy status of that property as well.
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CRCM, CAFP, DAD