Section 1071 of Dodd Frank raises a big question mark because it involves "small business loans" which are defined in a different way than CRA does. Supposedly the CFPB was going to issue an advanced notice of proposed rule making for 1071 this fall, but so far no sign of that. Because 1071 defines small business loans differently than CRA it is unclear how CRA itself may be affected, but it sure will be confusing if the differences are reconciled. The new definition is much more expansive than the CRA definition.
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