Borrower operates a residential adolescent treatment program. They bought a house for people to live in as they progress in their treatment program over a period of several months up to a year or two. I think this is "transitory" so it would be excluded from HMDA. Thoughts???

I'd tend to agree, they most likely have permanent homes elsewhere, right?

When we have these requests, we do not report because as mentioned they are truly transient housing.