Here are the factors:

We opt not to report home equity lines of credit at our bank where HMDA is concerned.

If any loan has a home improvement purpose, we classify it that way and report it (except, as I just said, if it's a heloc).

That said, if we do a commercial line of credit to refurbish the units in an apartment building (making this a home improvement loan for HMDA), should it be considered a "heloc" since it's secured by the building, and therefore reportable? Or, if you look at it as a commercial line of credit for home improvement purposes, does HMDA give us the option of not reporting non-home equity lines of credit? (The reg only talks about home equity lines, not other types of lines - without this definition, I'm not sure how to interpret....)

Thanks for any guidance.....

My understanding is that any line of credit secured by a dwelling meets the definition of HELOC. We do not report any revolving lines of credit.

I agree. Any open-end LOC is exempt.

What about unsecured lines of credit for home improvement and classified in our records as such?

ANY line of credit is optional.