For a bank that is a large CRA bank and reports data, would a SBA 504 loan have to be reported first as loans to small business or can it be reported as a community development loan? Or can it be both? I was thinking only HMDA multi-family loans is the only exception to allow for two reporting categories.

For a large bank, if it's under $1MM, then it's a small business loan. If it's over $1MM, it doesn't qualify as a small business loan, and can therefore be included as a CD loan. It can't be entered as both.