We're exploring current CRA data reporting requirements for large banks. Every source I found including the FFIEC's Guide to CRA Data Collection cites the requirement to report small business / farm gross annual revenue of $1 million or less. But the Reg states the following:

(vii) An indicator for whether the loan was to a business or farm with gross annual revenues of $250,000 or less;
(viii) An indicator for whether the loan was to a business or farm with gross annual revenues greater than $250,000 but less than or equal to $1 million;
(ix) An indicator for whether the loan was to a business or farm with gross annual revenues greater than $1 million; and
(x) An indicator for whether the loan was to a business or farm for which gross annual revenues are not known by the bank.

So will we need to report simply $1 million or less, or are there 3 reporting tiers starting at $250,000? Can somebody help clear up my confusion?

The multiple tiers, with $250,000, are under the new rule, whose effective January 2026 data collection date is questionable, but at least delayed, due to the injunction. Until the new rule is effective the GAR is reportable as less then or equal to $1 mill, greater than $1 mill, or no reportable revenue.