The area generating the loan in the bank is moot. Borrowers, purposes and such are your concern. The fact that a truck loan was made by a commercial lender for the borrowers son as a graduation gift doesn't make it a business loan or exempt from Reg Z as an example.
Fair housing and Reg B rules apply to consumer and commercial loans, but you can avoid Reg Z issues, per 1026.3, "Credit extended to acquire, improve, or maintain rental property (regardless of the number of housing units) that is not owner-occupied is deemed to be for business purposes."
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AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell