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: Regulation B
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 […]
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 […]