If you are a bank that does not meet the asset threshold of large bank, do you continue to go by the threshold requirement to start reporting? Or do you go by the number of small business number of loans in prior 2 years?

Are you talking about CRA or 1071?

CRA

Which test are you choosing to be examined under? If you've chosen to be evaluated under the large bank test, you need to file.

Yes, we have the asset size 2.5 billion, but we do not have many we had 30 in 2022 small business loans. We file because of the asset size under CRA, now with 1071 we don't meet the number of loans to collect and report. I have not found any comments addressings this under Reg BB.

CRA and 1071, at least as of right now, are separate. If you had to file for CRA before, you still do. If you don't meet the threshold for 1071 filing, that means you don't have to file for 1071. It doesn't affect your CRA filing.

So in our case, the only change at the moment would be that the loan amount is no longer a factor and revenues are up to $5 million versus $1 million and wait until the date where all tiers must report.

CRA has not changed. Yes, there is a proposal that you can read, but as of right now, CRA has not changed. The modernization has not been finalized yet. Therefore nothing has changed in how you are reporting for CRA. The 1071 definition of small business does not affect or change your CRA reporting.

Chinchilla, I appreciate your input. I believe someone should be addressing Reg BB, all you hear is 1071 Rule and one is seperate from the other.
Thank you.

1071 and the differences in definitions is covered in the CRA modernization proposal. You can find it here: https://www.federalregister.gov/documents/2022/06/03/2022-10111/community-reinvestment-act
It's still just a proposal at this point though. We'll have to see what the final version looks like and when it becomes effective. Until then, business as usual as far as CRA is concerned.