The key is the Call Report instructions. If you make a loan to a non-profit it ordinarily is not included in the C&I item 4a, but rather in Item 9 and therefore may qualify for community development under one of its CRA definitions. However, if the loan is secured by non-residential non-farm property it would appear in item 1e, and if <=$1 million would be reported as a small business loan for Call Report purposes (and therefore for CRA purposes).
Any PPP loans would qualify and flexible, innovative or even complex and should be isolated for extra credit during a CRA exam.
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