Is a loan to a tenant of an apartment for the purchase of a spa reportable? I say no on both accounts, the tenant is not the owner of the real property and no to reporting the spa because it is not a permanent fixture.

If it's a "plop and plug" model, like a washer or dryer, I would say no. If it's a built-in and requires professional installation, yes.

So a tenant could have a home improvement loan even though they are not the owner and this would be reportable?

I know of nothing in the reg that requires the borrower to also be the property owner to qualify a loan as home improvement.

We've had it happen that a tenant got the loan to....oh, say, put down new carpet....a couple of times. Pretty rare though.

Because this is home improvement, remember that the loan either has to be secured by a dwelling (not necessarily the dwelling being improved) or has to be classified as a home improvement loan (if you classify and report unsecured home imp loans).

plus what she ^^^ said.

Ok Thanks!