Home Improvement-Line of credit

Have a loan for a line of credit to a commercial customer that is to make improvements to dwelling and then to sell home. Compliance One says this is HMDA reportable. But a line of credit loan we did last week to refi- a line of credit secured by a dwelling was not HMDA reportable. Is this correct? Also, if this is true...I have 3 borrowers - how do I show 3 on the government monitoring section?

This sounds like a draw note and not an open-end LOC therefore it would not be exempt.

In the case of more than two borrowers you report the first two on the LAR, however you retain the GMI for all borrowers in the file.

Thank you!