If your institution is still questioning which compliance tier you fall into for Small Business Data Reporting, Section 1071. If you have questions about covered transactions or just want to hear what the CFPB has to say on 1071 coverage. You’re in luck. The CFPB announced this morning that they will host a RegCast on the small business lending rule. It will provide information from the rule to help financial institutions determine whether they are […]
Category: CFPB
SECTION 1071 – SPECIAL TOOLS AND GUIDANCE
The final rule implementing Section 1071 of the Dodd-Frank Act is massive. There are a couple additional pieces of guidance that may offer relief to some institutions. The Consumer Financial Protection Bureau (CFPB) has provided a Filing Instructions Guide, a Small Business Lending rule: Data Points Chart, a Grace Period Policy Statement and a Statement on Enforcement and Supervisory Practices Relating to Small Business Lending Rule. Details follow. Filing Instructions Guide – The 2024 Filing […]
JOINT APPLICATIONS AND FINAL SECTION 1071
The proposed regulation to implement section 1071 did not address the handling of joint applications. This writer and others commented on the lack of guidance for reporting joint applications. Joint applications for commercial and agricultural loans are not common, but they do occur. The issue is whether information is collected for each applicant, or for a single applicant, and if a single applicant, which applicant. The final regulation, published on March 30, includes comment 103(a)-10 […]
CFPB’s Releases a Special Supervisory Highlights Report All About Junk Fees
Fee practices continue to be in the spotlight and with the release of the special addition of the CFPB’s Supervisory Highlight, it looks like they are about to get even more attention and scrutiny. The Highlights come within a few months of major enforcement actions and other CFPB guidance. Since the fall of 2022, three financial institutions have had the unfortunate experience of being cited and accused of having potentially unfair, deceptive, or abusive policies […]
CFPB UPDATES CONTACT INFORMATION
On March 20, 2023, the Consumer Financial Protection Bureau (CFPB) published a final rule to make non-substantive corrections and updates to CFPB and other Federal agency contact information found at certain locations in Regulations B, E, F, J, V, X, Z, and DD, including Federal agency contact information that must be provided with: The Equal Credit Opportunity Act adverse action notices; and The Fair Credit Reporting Act Summary of Consumer Rights. This final rule also revises the […]