To be clear, 1071 is replacing CRA reporting or is it in conjunction with CRA reporting?

The small business data collected under 1071 will replace small business and small farm data collected under CRA after 1071 is completely phased in. Community Development activity will continue to be reported under CRA as indicated in the 2022 CRA NPR.

You said that CD loans would still be evaluated under CRA and NOT 1071. Today however there is a prohibition on reporting loans as CD if they are already included on the Small Business LAR. If loans are 1071 reportable, will they be eligible to be considered for CD credit?

That is a very good question that can’t be answered until the prudential regulators issue the new CRA Rule, sometime later this year. I can only speculate that double-reporting small business and CD-qualified loans may be permitted when the new CRA Rule is published.