Would a loan used to purchase a property that contain a dwelling and commercial building that will be reportable for HMDA be reported as a small business loan since the dwelling was not taken as abundance of caution? But the primary collateral is the commercial building based on income and square footage. Below is from the Q&A.


The origination of a small business or
small farm loan that is secured by a oneto-
four family residence is not
reportable under HMDA, unless the
purpose of the loan is home purchase or
home improvement. Nor is the loan
reported as a small business or small
farm loan if the security interest is not
taken merely as an abundance of
caution.

Because your loan is reportable for HMDA, it cannot be double reported as a small business report for CRA unless it is a HMDA refinance. There is a carve out for HMDA small business refinances. You would have to back it out of your small business numbers because the HMDA reporting is mandatory.

The only double reporting allowed is the refi carve out mentioned above as well as the multifamily rule that allows a HMDA reportable multifamily property to be also reported as community development if it qualifies.