As you may already may be aware, the CFPB stated in its proposed rules regarding the data storage requirement that it is considering a community bank exemption to the rule — “as an alternative to requiring electronic records, that a class of entities consisting of small creditors be exempted based on either entity size or the number of loans originated” (page 261 of the proposed rule). In another part of the proposal, the CFPB states that the exemption threshold will likely be at $10 billion (page 612).