A 504 first over $1MM does not have to have a CD purpose. See Federal Register / Vol. 79, No. 175 / Wednesday, September 10, 2014 / Notices which notes what is an example of CD loan.
businesses, in an amount greater
than $1 million, when made as part of
the Small Business Administration’s
504 Certified Development Company
program;
504 firsts are considered to be CD loans because of the job creation/retention requirements for the program.