Lately, I have seem couple Appraisal Reports using "mixed-used property" when in fact there are two separate buildings (for example, a site improved with a one story retail building along the street frontage and a 2-story apartment building in the rear)

As far as I understand, the appraisor has to evaluate these buildings together because they are sharing the same APN.

As for CRA reporting purpose, can we still report this when the sq.ft. of retail building is bigger than the apartment? or it would be considered having a stand-alone residential property as collateral.

I would think when we say "Mixed-used property" for both retail and residentail use, it means those two purposes were used within the same building.

Please kindly let me know your thought about this? Thank you very much.

How is the bank reporting this collateral on the call report, as secured by non-farm/non-residential real estate or as secured by residential real estate? If the commercial building (the store) is of higher value, that is likely how it is classified on the call report and that is its classification for CRA and the loan would be a small business loan if the amount is $1 million or less.

If the loan is on the books as secured by residential real estate, it cannot be a small business type 1 for CRA but would be a type 3.

Don't confuse CRA with HMDA. The loan could still be HMDA reportable, for example if this meets HMDA requirements for a purchase, improvement or refinance. HMDA has no "primary use" when the structures are separate. In that case, unless the loan is a refinance for HMDA, it would be pulled out of the CRA small business reporting so that the loan is not double reported. Refinances can be double reported (refer to the q and a).