Purchase - Side Collateral?

We have a customer who is purchasing a residential condo. The thing is the main collateral is their IMA account, and we are also holding the primary residence as "side" or "abundance" of collateral. Since the primary residence has been included to some capacity does this make the transaction HMDA reportable for a purchase? Thank you.

Taking the real estate as an "abundance of caution" doesn't exempt the loan from HMDA. It sounds like the purpose of the loan is to purchase a dwelling and will be secured by a dwelling, so it will be a HMDA reportable purchase.

Great, that's what I thought as well but just need a second opinion.