or you do not even list home improvement loans in your product offerings than your regulator may object.
They may object but they would have no regulatory basis to cite you for any violation. The regulation does not specify you have to have a "home improvement program", all it specifies in order for a non dwelling secured loan to be reported is that the purpose be for home improvement and the financial institution classifies the loan as a home improvement loan.
Until we stopped reporting them in 2004 we had no home improvement program in our product offerings. All non dwelling secured home improvement loans were priced according to the loan type, i.e. auto, unsecured, CD, etc.
FWIW I agree with #12's and David's responses.