We had two PPP loans with loan amounts less than $500. I know for HMDA, loans less than $500 are not reportable, as they would be rounded down to $0. However, I've looked through the CRA Q&As and the reporting guide, and couldn't find a similar exemption for CRA. It makes sense not to report, because the amount would be $0, but I guess they didn't think this situation would ever come up. Any advice?

It has been a while since I have been actively involved in CRA compliance, and maybe this has just blown right over my head, but there is a reporting requirement at the individual loan level for CRA data reporting?

It's not a lot of information, but large banks have to report loan number, loan amount, whether the loan is a small business or small farm loan, and whether the business/farm revenues are greater than 1MM:

228.42

Right - that is data to be maintained - there is no rounding. You only round when you are reporting the aggregate categories.

Hmm, my CRA reporting software (Questsoft) requires the loan amount to be expressed as rounded to the nearest thousand. I did find that there's a checkbox for a loan amount less than $500.