Ok, We make a loan to individuals to purchase this 12 unit apt. complex. This particular project at least 51% of tenants earn up to 115% of area median income. Using a Community Investment Program(CIP) and Econnomic Development Fund Application the bank also applies to FHLB for CIP advance to cover cost of loan. We are a small bank so do not have to track investments for CRA.... my question, is this loan not HMDA reportable as a purchase of 5 + dwelling?
I understand you can't double count (CRA & HMDA) but it seems to me we should be able to get credit for HMDA.

This loan is HMDA reportable as a purchase. Multi family property loans can be double reported for CRA. Refer to the CRA Q and A. Search on HMDA.