Would mobile home parks be a case of double reporting since they are HMDA reportable and small business reportable?

I thought for CRA (which is no longer a strong point) that the property had to be non-residential?

Small business loans are defined as those whose original amounts are $1 million or less and that were reported on the institution’s Call Report as either “Loans secured by nonfarm or nonresidential real estate” or “Commercial and industrial loans.”

I my conversations with FDIC call report analysts they have stated that mobile home parks are non-residential improved real estate.

Then I would follow what your regulators expect. And if that is the case, then yes.