[TheBank]

For non RE secured home improvement loans, our “classification” system is fairly simple, it is by naming them home improvement or similar term on the purpose section of the loan boarding data sheet.

I found an unsecured consumer loan with purpose of “concrete” and when I asked the lender about it they said it was for the drive way at the borrower’s home. I think that installing a concrete drive adds to the value of property and meets the basic definition of HI for HMDA, and given how we name our HI loans that are not RE secured, it also meets that as well and should be reported on the LAR. Is that correct?

[Author]

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