On May 15, 2023, the CFPB released a Small Entity Compliance Guide. The guide was made available on the CFPB’s Small Business Information resource page with the purpose of providing a detailed summary of the final rule’s requirements. The CFPB states that the content of the guide does not include any rules, bulletins, guidance, or other interpretations issued or released after the date on the guide’s cover page.
Additionally, the CFPB expressly states that users of the guide should review the final rule as well as the 888 page final rule which is available on the CFPB’s website.
Key components of the Guide include:
- Illustrative examples to comply with the final rule. For example:
- Determining Covered Financial Institution Status
- Annual determination of coverage
- Covered transactions.
- Multiple requests
- Voluntary collection and reporting
- Collecting and reporting the data points.
- Additional information regarding the requirements for collecting, compiling, and reporting data.
- Additional information regarding the requirements for maintaining data.
- Collecting and compiling data
- Firewall
- Record Retention
- Reporting data to the CFPB
- Availability and disclosure of data
- Effective and compliance dates
We are working through the Guide ourselves and will continue to explore the Guide and provide valuable insights.
Feel free to visit the Section 1071 Resource page for the latest training, webinars, and free tools for the Small Business Data Collection and Reporting requirements.