I disagree KC. That is true for dwelling secured loans, but not unsecured or non-dwelling secured loans.
203.2(g)(2) defines a HI loan as:
A non-dwelling secured loan that is for the purpose, in whole or in part, of repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which it is located, and that is classified by the financial institution as a home improvement loan.