Below are the relevant compliance dates if you are a small bank or Intermediate Bank. Having provided the information below I am confident that the OCC 2020 CRA Rule will be changed within the year, so I wouldn't get too anxious about complying with the 2020 Rule at this time.
§ 25.01: (7) Compliance dates
(iii) Small and intermediate banks must comply with §§ 25.09, 25.22, and 25.25, as applicable, by January 1, 2024.
§25.09 - AA delineation
.§ 25.22 Retail domestic deposit data collection for small and intermediate banks evaluated under the small and intermediate bank performance standards in § 25.14.
A small or intermediate bank evaluated under the small and intermediate bank performance standards in § 25.14 must collect and maintain data on the value of each retail domestic deposit account and the physical address of each depositor as of the close of business on the last day of each quarter during the examination period until the completion of its next CRA evaluation
§ 25.25 Recordkeeping - Banks must keep the data collected under § 25.21, § 25.22, and § 25.23 in machine-readable form (as prescribed by the OCC) until the completion of their next CRA evaluation.
§ 25.21 pertains to banks subject to the general performance standards (i;e., Large Banks), and § 25.22 is quoted above and § 25.23 pertains to wholesale and limited purpose banks
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