Quicky - it sounds like you are asking about temporary financing by your bank of the CDC part of the 504 loan. That would qualify as a separate loan even if it is short-term. Usually, 504 loans qualify for CD credit but be sure to specify what definition of CD applies. The challenge with the small loan is it may be a small business loan if it was extended to the business borrower. If you are an ISB however, you may, on a loan by loan basis for ISB examination purposes, have loans that are both CD and small bus loans treated as one or the other for exam purposes only (if you voluntarily report your lending you would report a small bus loan that is also a qualified CD loan as a small business loan).
It's perfectly confusing, right!
Two small business loans to the same borrower can be claimed as 2 small business loans unless they are refi's or renewals in which case they are limited to the once-per-year rule.
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