The SBA loans don't qualify for CD credit simply because they are SBA loans. They must be for a qualified CD purpose, typically "economic development" which is interpreted to mean job creation, preservation or improvement primarily for LMI persons. They could potentially qualify under revitalization/stabilization if you can demonstrate the loan is consistent with a government plan for a targeted tract. Like any CD loan or investment you need the documentation to substantiate the CD purpose is being fulfilled.
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