"Covered transaction" is the term used and it is defined in 1026.43. It is any "consumer credit transaction that is secured by a dwelling, as defined in § 1026.2(a)(19), including any real property attached to a dwelling, other than [HELOCs and reverse mortgages]."
To meet the requirement, you look at a subset of covered transactions -- those that are first-lien secured by a property in an R/U area.
If the property address is reported by the Bureau's tool as located in an R/U area, you can count it.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8