Answer:
Sounds like a mixed use property. It will be the dwelling for the individual but also a "business" (providing services for clients). The lender needs to make a determination about the "primary use" of the property.
For 2017 rules: Look at Comment #4 to §1003.2 (Home Improvement).
For 2018 rules: Look at the Commentary to §1003.2(f)#4. You may also look at Comment #5 to this same section pertaining to medical and assisted living facilities.
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