It seems that a banker will need to determine if the loan they are taking an application for is a HMDA loan, a CRA loan or Section 1071 loan. It is possible that a loan will be reportable for CRA and not Section 1071. Is there any safe harbor if a banker thought it was a Section 1071 loan and collected the demographic information, but realized after the fact that it was not a Section 1071 loan and should be reported only for CRA? Answers: It is possible that a loan would be reportable under CRA and not reportable under 1071. Such a situation would occur if a business loan for $1 million were to be extended to a borrower with GAR >$5 million. There are safe harbors for unintentional mistakes in which the PDI was collected and should not have been. see 112(c)(3)

It is possible that a loan would be reportable under CRA and not reportable under 1071. Such a situation would occur if a business loan for $1 million were to be extended to a borrower with GAR >$5 million. There are safe harbors for unintentional mistakes in which the PDI was collected and should not have been.  see 112(c)(3)