The Regulation clearly states you have the choice of the principal office of the borrower or the use of proceeds. Examiners do expect consistency with the choice.
SECTION 228.12 Definitions
o) Loan location. A loan is located as follows:
(1) A consumer loan is located
in the geography where the
borrower resides;
(2) A home mortgage loan is
located in the geography where
the property to which the loan
relates is located; and
(3) A small business or small
farm loan is located in the
geography where the main
business facility or farm is
located or where the loan
proceeds otherwise will be
applied, as indicated by the
borrower.
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