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: Section 1071
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 […]
Update: Make that 19 Days and Counting! Section 1071 Final Ruling to be Announced This Month
Last week, we started a countdown for the impending final rule implementing the small business data requirements of Section 1071 of the Dodd-Frank Act. Well, the CFPB released it’s Fall 2022 Semi-Annual Agenda and it indicates the final rule will be released this month. That means the runway to prepare for the most significant regulatory update in decades just got a lot shorter. With that in mind and in order to help you get ready, […]