If you are not subject to HMDA reporting then you must collect monitoring information under the provision of Reg. B's 202.13. You are to collect monitoring information if the loan is for the purchase of the applicant's primary residence, or the refinancing of the purchase of the applicant's primary residence and the loan will be secured by that residence. Otherwise you would not collect monitoring information, such as a loan for consolidation purposes.
The opinions expressed are mine and they are not to be taken as legal advice.