Would a loan to a for-profit entity for less than $1M secured by
1) assignment of a 1st mortgage that is secured by residential property, and
2) assignment of the deed of the same residential property
be reportable as a small business loan?

Its this "assignment" part of it that is throwing me off. If not for the assigment, I'd say its primarily secured by residential real estate and therefore not reportable.

Loan amount is $760K. 1st mortgage valued at $800K; residential property valued at $955K.

How is the loan reported on the bank's call report? I imagine as secured by residential real estate because the mortgage has been assigned to the bank. In that case, it will not be a CRA small business loan if that is the primary collateral.

Its on the call report as 4/4a.

Unless I'm mistaken, call report code 4a equates to a small business loan. So it would be reportable, because the collateral is not residential real estate but the assignment of a mortgage and a deed to residential real estate?

Or does "assignment" mean the loan is still secured by residential real estate so regardless of the call report code, it should not be reported?

I'm not sure what the call report says about assignments but if the person that held the mortgage has assigned it to the bank and the bank now "stands in the shoes" of the original mortgage holder the loan would be secured by real estate.

Check with the folks who handle your call report to make sure the loan is properly coded.

Otherwise, yes, 4a are small business loans as well (commercial and industrial).