Will CRA Large Banks still need to report their loan data after this regulation take effect?

It is reporting small business image likely that CRA reporting would continue during the transition period. But after that (beginning in 2026) small business and small farm loans under CRA will likely be discontinued being reported under CRA.

I see that TBA/Texas bank have sued CFPB-could this stall the implementation date?

Possibly if the court issues an injunction.

Are credit unions required to comply with DF1071?

Yes

Can you explain the firewall section? Would it be less likely to get dinged if we just have every customer sign the model form?

For most community banks it will be impossible to separate the Personal Demographic information – the banks are small and they are in communities where everyone knows everyone. I would develop an internal memo documenting your policy and practice regarding the firewall and explaining why you can’t keep the PDI from certain decision makers. It may be possible to keep the information from some decision makers, but there may be others from whom it can’t be kept separate. I would definitely have in written policy that the information is not to be discussed in credit committees where credit decisions are being made and that those decision makers who know the PDI information are not to discuss it with anyone involved in granting the credit.