Could someone please clarify is this should be a consumer disclosable loan. Loan proceeds will be used to refinance a business loan on a mixed use building (retail downstairs and one owner-occupied apartment upstairs) and cash out to pay off credit cards and closing expenses. The business loan was used for improvements to the restaurant and operating capital. Thank you.

Loan proceeds will be used to refinance a business loan . . . and cash out to pay off credit cards

If the primary purpose of the loan remains for a business purpose then it will remain exempt. If the primary purposes has shifted to consumer, i.e. the credit cards are personal and the amount to pay them off exceeds the business loan payoff, then it becomes a consumer loan and would be disclosed as such.