Assuming this isn't a refi, it would not be reportable based on what you provided.
The way you get to this answer is a bit complex, so let me try to quickly explain. First, you need to determine if this is a dwelling by definition by determining the primary use of the property. If the primary use is commercial, it isn't reportable. If the primary use is consumer (which in this case, it could be) we then need to look at the mixed-use rule for Home Improvement loans. Since the funds are not for the residential portion of the property, but are for the commercial portion, this would not be a home improvement purpose. Therefore, this would basically be an "other" purpose, commercial-purpose loan, which is not reportable.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com