If you make SBA loans are you subject to CRA even if you are simply a lender and don't take deposits?

From the CRA Guide:

"Who Must Report
All state member banks, state nonmember banks, national banks, and savings associations that meet or exceed the asset size thresholds for both of the last two calendar years are subject to the data collection and reporting requirements of the CRA."

These are institutions regulated by the OCC, FDIC, OTS and FRB. If you are some other type of lender, it would not apply.

Thanks