UBIT and my self-directed HSA

[John Jacobs]

Hello Bigger Pockets,

I was wondering whether my self-directed HSA would incur UBIT in the

following scenario:

There will be a conventional loan (i.e. a bank) in first lien position.

My self-directed HSA will be in second lien position. My self-directed

will be a straight debt lender and will charging points and a % per annum

let's say 2 points and 12% per annum.

Will my self-directed HSA be subject to UBIT?

If not would you explain why?

Thank You

John Jacobs