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.