If we have a commercial loan to rent RV lots out, would this be considered reportable for CRA? They are vacant lots, of course, until they are filled with RV's. Thanks in advance.

The collateral is the lot (Land)? Then IMO it would not be reportable. Now if you took as collateral the receivables for the rental then you would have a reportable loan.

If your collateral is the RV lots, take another look at it. Is there some sort of building such as a rental office, pool, laundry room on the site?

If there are hookups as is typical with RV sites, there should be improvements such as power, water and perhaps sewer as well as concrete pads to each site. Is this really considered vacant land?? Can vacant land generate rental income?