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.
Regulations are a poor substitute for ethics.
Just sayin'