If one lists SD-IRA assets on a loan application can the IRS consider that self dealing?

[Jeff Rabinowitz]

Fannie Mae allows a lender to consider assets in an IRA when analyzing a personal loan application. If a borrower lists assets in a self directed IRA on a loan application to obtain a personal loan that they would not have qualified for without consideration of the SD IRA assets they are receiving a personal benefit from the IRA. Can the IRS consider that self dealing and use that to force distribution of the SD IRA? Since the penalties for self dealing are draconian is it worth the risk?