I have a lender asking me if a loan would be qualified as a community development loan, and I honestly don't know the answer....

The loan is to a homeowners association to purchase a sewage system that services the homes in their HOA. The loan will be a USDA Rural Development guaranteed loan. The USDA RD fact sheet I was given says that its loans meet the requirements of CRA.

However, the HOA is in an upper income census tract, and the MHI for the homeowners, provided by the HOA, is above AMI.

So, I know its a USDA RD loan, but when I look at the homeowners it is benefitting, I don't think it will pass as CD.

Am I missing something? Are USDA guaranteed loans automatically given consideration?

USDA Community Facility RD loans do not automatically qualify, and the only requirement of the program is that the funds be used in a rural area. I would say based off of your instincts the loan lacks the primary purpose to be considered CD.

Here is the USDA RD Community Facilities FAQ: https://www.rd.usda.gov/programs-services/community-facilities-direct-loan-grant-program