Yes, but if the loan isn't subject to Reg Z at all (non-owner-occupied rental property, loan to acquire, improve or maintain same), no part of Reg Z will apply, and you won't report total costs or points and fees in HMDA.
And that is true even if the lender delivered TRID-like disclosures that included total costs and/or points and fees.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8