Additional FAQs Released by CFPB on Section 1071

Today, the CFPB released additional, more extensive Frequently Asked Questions on Section 1071, Small Business Data Collection and Reporting requirements. The expanded list of questions extends beyond the Institutional Coverage and Small Business/Credit transactions they released in June of this year, to include guidance on Firewall and Record Retention. In addition to the new sections, the CFPB also added additional questions and more details to the prior sections of the FAQ.

It is important to note that the CFPB included a disclaimer for any Bank currently protected by the U.S. District Court for the Southern District of Texas’s stay order. However, they still expect all other financial institutions covered under the rule to adhere to the compliance dates detailed in the final regulation.

If your institution has not yet determined its tier or is still in the process of trying to create a good methodology for tier determination, reviewing these FAQs on Section 1071 would be beneficial because the CFPB outlines their expectations on how FI’s ought to determine their compliance tier in them.

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