Now that the Section 1071 rule is final, should we still be doing CRA Small Business as we do currently until we must begin the 1071 small business data collection based on the tier applicable to our loan volume?
The OCC, the FDIC and the FRB in their 2022 notice of proposed rulemaking regarding CRA indicated that when the 1071 reporting begins CRA covered banks will no longer have to report small business and small farm loans under CRA, because they will be reported under 1071. However, community development activity will continue to be reported under CRA.
For HMDA loans that are also reportable as CRA CD reportable loans now, can we still report them as a CRA CD loan? And if yes, will that change based on the compliance date tier? Please explain.
Regarding HMDAa reportable loans that are also qualified as community development, i.e. multi-family, affordable housing, those will continue to be reported under HMDA and under CRA. Section 1071 does not collect any community development data. Who reports that Data under CRA will be determined in the revised CRA rule when it is published.
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