I think you are going to have to make the call whether this is long-term housing for the residents or not. A property used for both long-term housing and to provide assisted living or supportive housing services is a Dwelling. If you decide it is reportable, I think it would be four units regardless. The other question is you say you are "reviewing a loan secured by". What is the purpose of the loan?
Properties used to provide medical care, such as skilled nursing, rehabilitation, or long-term medical care, are not dwellings. If a property is used for long-term housing, to provide related services (such as assisted living), and to provide medical care, the property is a dwelling if its primary use is residential. Comment 2(f)-5.
A financial institution may use any reasonable standard to determine a property’s primary use, such as square footage, income generated, or number of beds or units allocated for each use. It may select the standard on a case-by-case basis. Comments 2(f)-4 and -5.
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