We have a loan for the purpose and use of proceeeds is to puchasing land for future development.
the collateral used is mortgages on real estate other than the real estate being acquired with the loan proceeds: Collateral: two income producing properties that are improved with operating restaurants. (still the proceeds are not being used in the restaurants)

I don't believe the collateral has anything to do with the prupose of the loan. Would the purpose in this scenario even qualify for CRA Small Business?