Where are you getting that this is applicable to CRA?

2022 NPR says 1071 data will replace CRA small business and small farm loan data.

Does this mean that Participations are excluded and considered not a covered transaction?

Yes - Credit transaction purchases, purchases of an interest in a pool of credit transactions, and purchases of a partial interest in a credit transaction. The term “covered credit transaction” does not cover the purchase of an originated credit transaction, the purchase of an interest in a pool of credit transactions, or the purchase of a partial interest in a credit transaction such as through a loan participation agreement. Such purchases do not, in themselves, constitute an application for credit. See also comment 109(a)(3)-2.i.