Archive

CFPB Responds to the TBA, ABA, and Rio Banks’ Lawsuit

On May 4, 2023, Compliance Resource blogged on the lawsuit challenging Section 1071 final rule, released by the CFPB in March of this year. The CFPB  filed an opposition to the lawsuit in June claiming the plaintiffs have not established their standing for relief or that venue is proper in the Southern District of Texas because: Rio Bank alleged in the complaint that it made 409 small business and agricultural loans in 2022, per the […]

CFPB Released FAQs for Small Business Data Collection and Reporting

On June 28, 2023, the CFPB released a set of Frequently Asked Questions to address for determining institutional coverage focused on areas like: Financial Institution Coverage Metropolitan Statistical Areas (MSA) Types of transactions Ag purpose credit Refinancings Temporary loans What to do if you did not collect Gross Annual Revenue for 2022 and 2023 Covered Credit Transactions and Small Businesses Covered credit transactions What is a small business Individuals and sole proprietorship The purpose of […]

CFPB – RegCast Announced for July 25, 2023

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 […]

A Small Business Entity Compliance Guide Added to the CFPB Small Data Collection, Section 1071 Resource Page

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 […]

TBA Files Suit to Block Section 1071

Last week, the Texas Bankers Association filed a suit to block the CFPB’s implementation of Section 1071’s final rule. The lawsuit was joined by TBA member, Rio Bank out of McAllen Texas. As you know, Section 1071 of the Dodd-Frank Act requires the collection and submission of data relating to credit applications by women-owned, minority-owned, and small businesses. TBA President and CEO Chris Furlow said, “CFPB has taken 3 pages of legislation requiring 13 data […]