Answer:
The collateral is reported as "Investment" because it is not the borrower's principal or second residence. That situation will always be "Investment" for HMDA. Investment does not mean only rental properties for HMDA reporting.
There are only 3 HMDA occupancy choices:
"Whether the property identified in paragraph (a)(9) of this section is or will be used by the applicant or borrower as a principal residence, as a second residence, or as an investment property."
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