The only lending activity that gets reported under CRA is small business loans, farm loans, and community development loans. Any other activity including the elective types of consumer loans (credit cards, auto lending,, etc.,) never gets reported. What happens is if you capture that data it is retained in the "micro-data" file on your desktop. When you are about to undergo a CRA exam, you can inform the EIC that you want the exam to include certain types of loans for which you have collected activity and scrubbed and edited the data (you have to establish a basis for the examiners to trust the integrity of your data).
The regulators will evaluate your home mortgage lending "whether or not the bank is required to report under HMDA", but it will be evaluated as it would be if it had been reported. BTW, a dwelling secured loan will never be considered a small business loan if it was for the purchase, refinance or improvement of a residential property.
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