Would it matter if a commercial loan is secured by a guaranty, which is secured by a residential dwelling in considering the loan as CRA reportable?

Nope, it's still secured by a residential property. It's a type 3 but if you feel special about your type 3's you could always share them for extra credit

I take a conservative view, but if the loan isn't 100% secured and you took a deed on the place...well you've got a dwelling you're looking to for repayment in case of default and that makes it type 3.

Thanks, that is what I was thinking, but of course got questioned on it. So other that taking it as an abundance of caution there is no way around having to code these as a 3.

One question - is the loan you are reviewing an SBA loan, and the property secured guaranty was required by SBA?

If so, I don't think those loans are really "secured" by residential property since you generally also get a UCC filing on just about everything for the business.

The SBA just likes to attach just about anything they can, and I've seen these silly residence secured guarantys in 3rd and 4th position where there is no hope of acquiring any value. I think its a "psyche" thing on the part of the SBA. And a real paperwork pain in the butt as well.

No, it is not an SBA deal. The note is secured by non-real estate business assets and there is a personal guaranty secured by the home.