The definition of a small business loan based on revenues and loan size. And how does that differ from the definition of a CRA small business loan? Thank you.

Loan size will not be relevant under 1071 unlike CRA where it is determinative. Under CRA you could make a $1 million loan to Walmart and that would be a reportable small business loan. But it would not be a covered application from a small business under 1071.

The regulators have stated that 1071 reporting would replace current small business/small farm reporting. That said, we also currently report Community Development loans with the same CRA LAR but I don't see any reference to CD loans in any of the materials. I am assuming that the revised CRA rule will address this but for now I am left wondering: Will we still have to report CD loans? If we do, will we be required to file them separately from 1071 loans thereby still effectively requiring 3 LARS? Currently, if loans are reported on the CRA LAR, they cannot also be reported as Community Development. Will we still not be able to "double report?" Since 1071 redefines covered loan, this could exempt a lot of loans we currently get CRA credit for as CD loans.

Yes small business loans as defined in 1071 will be reported under 1071 and the CRA requirement to report small business loans will be eliminated. However, community development loans will continue to be reported under CRA and it has been proposed in the 2022 CRA NPR that CD loans will be reported in much greater detail than now