We know that loans will be reportable for both CRA and 1071. What if we collect Demographic
Information and the loan ends up being reportable for CRA?
Being reportable for CRA does not
disqualify a covered transaction from being reported under 1071. The PDI would be reported
under the obligation imposed by 1071.
Which Data Points are interpreted differently from 1071 to HMDA?
Geocoding would be based on what the Rule calls the “Waterfall” approach which dictates the preferred option is based on the location where the proceeds are used. If that is not known, the address of the headquarters of the borrower would be the second choice for geocoding, Finally, if neither answer is available, geocoding should be based on another address associated with the borrower.
Which geocode “Source of Truth” should be used for CRA /1071 (FFIEC? CFPB Tool when it is
The safe harbor provisions in 1071 offer safe harbor for geocoding errors for records
geocoded using the CFPB’s geocoding platform.
Does 1071 replace collecting small business data under CRA or will we now be collecting under
2 rules? Eventually all small business data will be reported under 1071 and the obligation under
CRA will be eliminated. The question is what happens during the transition period. It’s likely
that for 2024 and 2025 reporting will be mandated under both rules
Is loan size irrelevant under 1071? -Yes
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