SBA 504 loans are presumed for the purpose of community development. You still have to prove the community development purpose on loans made under the 7A program.
§ll.12(h)—1: What are examples of
community development loans?
• Businesses, in an amount greater
than $1 million, when made as part of
the Small Business Administration’s
504 Certified Development Company
program.
If you are an ISB and not submiting your small business loan data anually to the regualtors, then you can capture loans for less than $1 million for CRA credit.