We did a loan for the 1/8th interest purchase of a 'phase' of condo's. This exclusive country club has two phases of condos, our borrower purchased Phase II/Four-bedroom which means that they may stay in any of the 6 Four-bedroom condos in their phase when they stay subject to availability. Their purchase is evidenced by an Undivided Deeded Interest. There is a member elected Board of Directors for each Phase of condos to which members can veto decisions made on budgets and annual dues.
They are guaranteed two summer weeks and two winter weeks (reserved six months ahead) annually and can stay virtually any other time they wish as available. They pay a housekeeping fee after each stay for gratuities, daily housekeeping and checkout cleaning.
Even though this is not a specified week(s) as in a timeshare, and they have a recorded deed in a specific unit, I don't see reporting this for HMDA as a second home. It seems more transitory (I even found nightly/weekly rates on their website I assume are for units not reserved by members) I'm being guided otherwise by the powers that be. Any thoughts?

We would not report this as it would be viewed similiar to a time share.

Thank you for your response JSD!