Unveiling the Implications: How Section 1071 Reshapes Community Reinvestment Act Reporting

In this podcast episode, Dean and Len discuss the implications of the new Section 1071 rule, which extends beyond the banking community. Len highlights that the number of reporters under Section 1071 is estimated to be four times greater than under the Community Reinvestment Act (CRA). They focus on the impact of Section 1071 on CRA reporting. Len mentions that the Office of the Comptroller of the Currency (OCC), Federal Reserve Board (FRB), and Federal Deposit Insurance Corporation (FDIC) announced their intention to replace the reporting of small business and small farm loans under CRA with Section 1071 reporting. Additionally, the definition of a small business loan will change, and the Section 1071 definition will replace the CRA definition.

Len emphasizes that this change allows for unlimited loan sizes based on the size of the business, not the loan. This has significant implications for CRA. Furthermore, Len discusses how Section 1071 may affect community development lending under CRA and raises questions about how the regulators will treat loans reported under both Section 1071 and CRA. Len also mentions some aspects of Section 1071, such as protected demographic information and reporting the course of action for small business loans, that will not impact CRA.

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