Yes and no. There does have to be a dwelling securing the loan in order to be HMDA, but if you are looking at a dwelling secured commercial loan, it still has to be purchase, HI, or refinance to be HMDA. There is no 'Other' for commercial loans as there is for consumer.
Also, watch out for what is a 'dwelling' under the new rules. A mobile home park is a dwelling for HMDA even if there are no mobile homes. And a mobile home constructed before June 15 (?), 1976 is not a dwelling (not sure of the exact date off the top of my head). There are a few odd quirks like that in the new rule.
_________________________
'Never' is karma's doorbell.
Ding ding!
It's for you. . . .