You "double" count them. Check out .22(a)(2)-7 in the CRA Q&A.
§ll.22(a)(2)—7: How are
refinancings of small business loans,
which are secured by a one-to-four
family residence and that have been
reported under HMDA as a refinancing,
evaluated under CRA?
A7. For banks subject to the Call
Report instructions: A loan of $1 million
or less with a business purpose that is
secured by a one-to-four family
residence is considered a small business
loan for CRA purposes only if the
security interest in the residential
property was taken as an abundance of
caution and where the terms have not
been made more favorable than they
would have been in the absence of the
lien. (See Call Report Glossary
definition of ‘‘Loan Secured by Real
Estate.’’) If this same loan is refinanced
and the new loan is also secured by a
one-to-four family residence, but only
through an abundance of caution, this
loan is reported not only as a
refinancing under HMDA, but also as a
small business loan under CRA. (Note
that small farm loans are similarly
treated.)
It is not anticipated that ‘‘doublereported’’
loans will be so numerous as
to affect the typical institution’s CRA
rating. In the event that an institution
reports a significant number or amount
of loans as both home mortgage and
small business loans, examiners will
consider that overlap in evaluating the
institution’s performance and generally
will consider the ‘‘double-reported’’
loans as small business loans for CRA
consideration.
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You keep using that word. I do not think it means what you think it means.