It's the loan size that matters. If this were a participation in a $1.1 million loan then it would not be a small bus loan and could be reported as a CD loan. But in this case there are two totally distinct loans and your loan is under $1 million so it must be reported as a small business loan unless some other factor would disqualify it as a small business loan. I would encourage you to collect information on loans like these to share with examiners who may take into consideration these loans to temper their judgment about your CD lending performance if you engage in a substantial volume of loans such as these.
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