Compliance officers from around the country have overwhelmed us with questions about the final Small Business Data Collection and Reporting requirements from Section 1071 of Dodd-Frank. Since March 30th we’ve been fielding these questions, researching answers, and providing them to our training clients and Compliance Masters Group subscribers. We thought our blog subscribers might also find this helpful and would like to share with you a free, on-demand Q & A session answering 10 of […]
Tag: ECOA
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 […]
PARK NATIONAL BANK REDLINING CASE
On February 27, 2023, the Department of Justice (DOJ) entered into a consent order with Park National Bank. The Order alleges that Park National Bank (“PNB”) engaged in a pattern or practice of unlawful redlining in violation of the Fair Housing Act (“FHA”), and the Equal Credit Opportunity Act (“ECOA”), and Regulation B, by discriminating on the basis of race, color, and national origin. Specifically, the United States alleges that PNB engaged in: Illegal redlining […]
UPDATE ON APPRAISALS AND DISCRIMINATION
On February 14, 2023, the Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, U.S. Department of Housing and Urban Development, National Credit Union Administration, Federal Reserve Board, U.S. Department of Justice, Office of the Comptroller of the Currency, and the Federal Housing Finance Agency (the “agencies”) sent a joint letter to The Appraisal Foundation (TAF) expressing concerns with the Fourth Exposure Draft of Proposed Changes for the 2023 Edition of the Uniform Standards of Professional Appraisal Practice […]