Tough one to classify - we have a commercial loan on a 52-bed facility that is home to mentally-challenged individuals. It's similar to a nursing home in that medical care is provided on-site. The residents don't have homes elsewhere (making it dis-similar to a dormitory).
The facility operates under a contract with the state, but is privately owned & operated. Residents live there permanently, unless their condition deteriorates to the point where they need 24-hour care.
It qualifies as a non-owner-occupied refinance - but is this a HMDA-reportable deal?
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