Are the SCRA Notice and/or the Homeownership Counseling Notice required to be sent on a commercial loan that becomes delinquent if one of the personal guaranties on the loan is secured by the guarantor's residence?

It's kind of a fine hair to split since the loan itself is not secured by the residence, and I have not been able to find anything definitive.
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'