We have a commercial line of credit that is secured by a multi-family dwelling. Our bank does not report Home Equity lines of credit, but does this one fall through the cracks? Page C-3 in the HMDA Getting it Right book states:

Home-equity line of credit means an open-end credit plan secured by a dwelling as defined in Regulation Z.

Reg Z says a dwelling is 1-4 family.

Do I report or not? Would this be in the sane categirt as a Home Equity Line of Credit

Would it fit CRA?

I wouldn't, the purpose is not to purchase, refi, or improve a dwelling.

I wouldn't report it as a small business loan either. With multi-family RE securing the LOC, you'd have to call code it REMU, so it wouldn't qualify as a small business loan.