Borrower has a commercial working capital loan secured by land that contains a mobile home park. Bank only has a mortgage on the land; none of the dwellings present (all are owned by the renters).
He needs to upgrade the sewer system so that he can increase the number of rental slots.
Our loan will not be secured by any dwellings (only the land) and will not be classified as home improvement.
HMDA reportable?
Thanks in advance.