When a loan is secured by a 1-4 family dwelling that is used as an investment property (non-owner occupied) this would be considered business purpose and therefore exempt from Reg Z, right?
Based on what I've read, if a loan is exempt from Reg Z, but still HMDA reportable, then we do not have to calculate the rate spread and HOEPA status on those exempt loans - do you agree to that?

Karen Sue, you still need to look to what the funds are being used for before you can determine whether or not it is a business purpose loan and therefore exempt from Reg Z.