If a natural person refinances their rental house (non owner occupied) should it have a rate spread on the LAR?

This question may have been answered before but I can't find it. FYI: I'm hesitant to use a Reg Z definition (business purpose or similar) for a HMDA (Reg C) question. Any help is most appreciated.

If the loan was made as a business purpose loan by your bank, there is no rate spread for HMDA or anything else.

Thank you Kathleen. I guess you're applying the Reg Z definition to a HMDA issue?

Or are you looking to determine whether the loan was made under the states consumer credit law or the commercial law (i.e. consumer promissory note vs. commercial note).

HMDA references Reg. Z and says not to report a rate spread for a loan that isn't subject to Reg. Z. So it's not a gray area.

Thank you very much.

If your loan is business purpose under Z, it is business purpse and no rate spread will be calculated. You will not have an APR, APOR, or any other rate issue for HMDA.