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 […]
Tag: ECOA
8 Steps to Prepare Your Frontline Staff for Section 1071
The frontline staff at financial institutions are often referred to as “the face” of the organization. They interact most with clients and are largely responsible for fostering positive relationships with your customers. But as a compliance professional, you’re well aware of the impact frontline staff can have on your institution’s ability to pass regulatory muster. Your institution/compliance department has likely already begun taking steps to prepare for the new Small Business Data Collection requirements of […]
We’re Overwhelmed with Questions about the Section 1071 Final Rule
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 […]
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 […]