Business equity line of credit (less than $1,000,000) to non-profit organization, secured by a multifamily residence (transitional housing). The organization contracts with the Federal Prison Bureau and is a reentry residential center that provides housing, food and services that help residents make a transition back into the community.
Is this a CDL? Don't see it as a small business loan as it is secured by a multi-family which is not CRA Reportable. Not HMDA reportable as it is transitional housing. Similar to scenario at this link,
https://www.bankersonline.com/forum/ubbthreads.php/topics/1989520/HMDA_purchase_or_CRA_community, however using the Dallas Fed CRA Loan Data Collection Grid I couldn't find a classification for it.
Thanks.