Is a loan to a homeowner's association considered a CRA loan? In this instance, they are wanting to use the funds to pave some of the neighborhood's roads and patch/repair others, as well as clean ditches.

Unless I am missing something, I don't see this as having a community development purpose.

For CRA, community development is: affordable housing (including multifamily rental housing) for low- and moderate-income individuals; community services targeted to low- and moderate-income individuals; activities that promote economic development by financing small businesses or small farms (gross annual revenues of $1 million or less); and activities that revitalize or stabilize low- and moderate-income geographies.

What dictates "small business loan" is defined in the Call Report. How has the loan been reported for Call Report purposes? Typically item 1e or 4a are where small business loans are captured.