We have two loans that were used to purchase a multifamily piece of property. The first loan is for $2.5 million and the second is for $450,000. I know that HMDA and CRA apply to both loans (for multifamily property), however, the first loan is for greater than $1 million dollars and those are not usually reportable for small businesses. I'll do HMDA and CRA for the smaller loan, and I'll do HMDA for the large loan, but do I need to CRA the large loan??

If the loan is over a million in size it's not reportable for CRA LR purposes. It may however qualify for CD credit, so that's worth pursuing.

Wow, Dawnie. You are quick.

Also, the small loan ($450,000) would not be CRA either (unless it is reserved for affordable housing and is reportable as community development). Multi-family properties do not meet the definitions for "Small Business Loans" under CRA. They fall outside of the Call Report sections 1E and 4.

I'm sorry I should have spelled out my answer more combine my answer and arye's answer and you have the complete answer

Multi Family deals are going to be either type 3, 9 or HMDA but can ALSO be CRA CD reportable if they fit the CD bill. (The property does not need to be reserved though... just "affordable")