A customer wants to borrow 15k against his home for the purpose of purchasing business equipment. This is a business purpose loan.

From my understanding this loan, even though secured by a home, would be exempt from the FFIEC APR HPML guidance due to it being business purpose. Is this correct?

If it meets the business purpose exemption of Reg. Z, it's exempt from the HPML requirements found in Reg. Z, yes.

Thanks.