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New Small Bus. LAR, Does it Duplicate HMDA

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Question: 
Regarding the new small business data reporting requirement expected to come out soon. Will this "1071" requirement be similar to HMDA and CRA whereby if it’s HMDA it cannot be reported as CRA? So if it’s a HMDA reportable loan, then we won't report it for the small business data?
Answer: 

Frankly, we don't know yet what the relationship, if any, between the new "Section 1071" reporting requirements and Regulation C (HMDA) will be when there is a small business loan that is also HMDA reportable.

First published on 06/04/2023

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