My LOS is calculating a rate spread on the HMDA screen for a loan marked at Primarily Business Purpose. Am I correct in thinking we would report NA for this non consumer use purpose?

If the loan is not subject to Regulation Z, you report NA (or Exempt if that applies with the new rule changes).

Great! Thanks!

What if the investment property is closed on consumer and TRID documents? Would we report the rate spread or just NA?

We provide the TRID documents on our business purpose/rental properties due to investor requirement. We are still going to report NA for rate spread. I believe there was a prior discussion on here about that......

We were planning to do the same, though luckily we are exempt. However, prior to the exemption we reached out to both the CFPB and FDIC and there actually was a consensus that what mattered was the primary purpose of the loan. The issuance of TRID disclosures due to investor requirements did not "make" the loan a consumer loan. This, however, highlights the need to ensure that there is proper documentation of the purpose of the loan.