Answer:
Only if your institution classifies such a loan as home improvement. HMDA uses two separate parameters for home improvement. The first, if the loan is for home improvement purposes and is secured by a dwelling. These loans are HMDA reportable as home improvement. Clearly that is not this described loan. The second, if the loan is for home improvement purposes, is unsecured or secured by collateral that is not a dwelling. These loans are only HMDA reportable if the institution classifies such loans as home improvement loans on its books.