If you are taking a lien on a building with 5 units, it's not a dwelling under Reg B. If you are making five separate loans on idnvidual condo units that happen to constitute all of one building, each loan is considered separately and you would have five separate dwellings for purposes of Reg B.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8