We are making a loan to a very large local non profit foundation that will be secured by 1 commercial and 3 residential properties (all acquired in last 3 years from foundation cash reserves). The properties are leased to other non-profit's who operate a job training/placement center and in the case of the residential properties - 2 half way houses for recovering addicts and a transitional house for homeless individuals. Is this loan HMDA reportable and if so, is it considered a refiance and I just choose one of the residental properties for tract data.