I just wanted to comment here because I had a client tell me they "heard" that rental properties are subject to HPML. I asked where they heard that, and the reply was another bank. I pointed out a loan to aquire, refinance or improve non-owner occupied rental property is specifically excluded from Reg. Z coverage. The only reason such a loan would be subject to Reg. Z was if a consumer pulled equity out of a NOO Rental to use that money for a personal, family or household purpose. That might be where the confusion is coming from.
Regulations are a poor substitute for ethics.