Got one on the books that's a little unusual. The renters borrowed money to purchase a heating unit for the home they rent and used a vehicle as collateral. The landlord is the borrower's mother so it's a "family affair". Is this reportable?
If it is, do we report as non-owner occupied but use the borrowers' race/sex?

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Is this reportable? If it is, do we report as non-owner occupied but use the borrowers' race/sex?

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Yes (if classifed as a HI loan), yes and yes.

I'm with Dan. The "family affair" issue has nothing to do with it.