Situation:
commercial Line of Credit for $200,000 secured by all business assets and mortgage on residential real estate.
Our bank is not required to report LOCs as HMDA at this point
LTV on the real estate is 44%.

According to the instructions for the Call Report: Loans secured by nonfarm residential real estate used to finance small business must be reported as “loans secured by real estate” when the real estate collateral taken is greater than 50 percent of the principal amount of the loan at origination.

Given it's not reported under HMDA, AND the LTV is less than 50 %, am I correct in reporting this as a small business loan?

Yes.

Since the Large Bank Examination is the foundation of all other CRA exams feel safe to use the Loan Data Collection Grid to determine if your loans fit into CRA. https://www.dallasfed.org/~/media/documents/cd/pubs/craloan.pdf.