We're not a CRA reporter but I do have the following FDIC link from 2005 that might give you a starting point.
https://www.fdic.gov/news/financial-institution-letters/2005/fil2905a.htmlAs we noted in the supplementary information section of the joint
interim rule, because of the change in the Regulation C definition,
loans to refinance small business or small farm loans, where a dwelling
continues to serve as collateral solely through an abundance of
caution, will now be reportable as refinancings under Regulation C.
Those loans will also be reportable for Call Report and Thrift
Financial Report purposes as small business or small farm loans,
resulting in the potential for ``double counting'' of these loans in
CRA examinations. See 69 FR 41184-85.
Two community organization commenters asserted that our CRA
regulations should prohibit such double reporting of small business
loans and small farm loans secured by residential real estate for
purposes of CRA. The agencies are not changing the CRA regulation to
address the commenters' suggestion. The suggested change would likely
increase the data collection and reporting burden for financial
institutions, without increasing the effectiveness of CRA examinations.
As stated in the supplementary information to the joint interim rule,
the agencies do not anticipate that ``double-reported'' 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 or farm loans, examiners
will consider that overlap in evaluating the institution's performance.
Accordingly, the agencies are adopting the change based on the
Board's Regulation C revisions without modification. We are adopting
this change as it was published in the joint interim rule.