If we have a non-profit organization that was granted a HMDA reportable loan, do we need to complete a rate spread calculation for their reporting? The property involved is not an investment property, but rather, is to be a group home.

Who is your borrower? Natural person or entity? Is the loan both subject to Reg. Z AND secured by a dwelling?

From HMDA-GIR Page A-8:

If the loan is not subject to Regulation Z, or is a home improvement loan that is not dwelling-secured, or is a loan that you purchased, enter “NA.”

Hope this helps.