We currently do not do CRA data reporting, how will the new rules affect if we report or not?

The new rule will not have any impact on who reports under CRA. However, Section 1071 will mandate who reports small business lending activity once it becomes effective. Section 1071 will require many lenders who are currently exempt from reporting under CRA to report under 1071. The reporting threshold will no longer be based on asset size, but rather the annual number of small business loans generated by the lender. The CRA will continue to mandate other data, particularly community development lending that is not covered by 1071, to be reported by covered lenders under CRA and that requirement will continue to apply to large banks as defined in the new rule ($2 billion assets when the definitions section of the new rule is "applicable".