We are a large bank and therefore report small business and small farm loans for CRA. I have found a couple commercial loans that are HMDA reportable (secured by multi-family), so they are not on the CRA LAR. However, they may qualify as affordable housing, since the rents being charged are below market rates.

As a large bank, can these loans qualify as community development even though they are less than $1 million?

Definitely!

Take a look at page three of the print version of the CRA Loan Data Collection Grid linked on the following website and you'll see both HMDA and Community Development are checked for the type of loan you're describing: https://www.dallasfed.org/cd/EconDev/cra

We always get community development lending credit for these types of loans provided the rents qualify as affordable.

Yes. This is the only exception to the rule about loans on the HMDA LAR not appearing in the CRA LAR.