Well,it is HMDA if it meets a HMDA purpose (purchase, home improvement, refinance).
If the mortgage is just a collateral mortgage for a non-HMDA purpose and the lien is not securing > 50% of the loan or is abundance of caution, it can be small business.
Last edited by Kathleen B; 02/10/1103:41 PM.
_________________________ Kathleen O. Blanchard, CRCM "Kaybee" HMDA/CRA Training/Consulting/Mapping The HMDA Academy www.kaybeescomplianceinsights.com