1st question: Is a loan CRA reportable if the first property held for collateral is a commercial real estate partially used as a retail store and the other part of the building are residential apartments (1st lien)and the second property held for collateral is the borrowers personal residence (2nd lien)? The purpose for this loan is to refinance an existing debt with another FI.

2nd question: if the only property held for collateral is a building / house used as two rental properties or two living units, be CRA reportable?

Thanks