If we deny a loan that is not dwelling secured but for the purpose of home improvement, is this still HMDA?

We can't classify on our system since we don't book it as such, but on our denial log we maintain we classify it as home improvement.

I think it would still be HMDA but wanted to see what others bank do.

If you normally classify and report originated non-dwelling secured HI loans then you will report all applications for that purpose. Denials, approves but not accepted, withdrawals, etc.