I’m not familiar with which loans qualify as CDL under ISB, however as a Large Bank some loans under $1,000,000 can be a CDL.
Think about:
• Non-real estate secured loans to non-profits that have a community development purpose,
• Construction loans in any amount – these are not CRA small business reportable. Look at the CT geography and if applicable will the construction have a stabilizing effect on the CT. Does the end result of the construction create permanent jobs for LMI individuals? Will those living in the CT patronize the business in question?
• Loans to municipalities for purchase of public service vehicles, etc. Again look at the CT geography and ask yourself if this helps meet essential community needs. Does this help attract new or retain existing businesses and residents? If the majority of geographies served are not LMI, then no CDL credit.
Familiarize yourself with the CALL Report and those items that are and are not CRA Small Business reportable, then look at the outliers. Also, read similarly situated bank's CRA PEs which may give you a sense on what regulators are looking for with regards to CDL.
This document from the OCC may help you determine what is qualified and what is not.
https://www.occ.treas.gov/topics/community-affairs/publications/fact-sheets/fact-sheet-cra-loans.pdf