As bjp mentions, be VERY careful. WHile the "house" is a business venture for the landlord, people still live there, which leads to HMDA. If you screw up your CRA LR you have some issues, but if you screw up the HMDA LAR...well you get to pay money for the effort
And that's YOUR money, not the bank
When you're downloading the GIR for CRA, be sure to download the current GIR for HMDA. If you don't have a HMDA officer to help you out....quit EVERYTHING you're doing and learn HMDA RIGHT NOW!!! It's a priority if you are making the determinations.