Congress directed the Consumer Financial Protection Bureau (CFPB) to adopt regulations governing the collection of small business lending data under the Dodd-Frank Wall Street Reform and Consumer Protection Act. Section 1071 amends the Equal Credit Opportunity Act (ECOA) under Dodd Frank, to require financial institutions to compile, maintain, and submit specific data to the CFPB on applications for credit for small businesses, women-owned, and minority-owned businesses.
The implementation of 1071 is proposed to be an 18-month window following the publication of the final rule, which will take place no later than March 31, 2023. RiskExec anticipates initial collection of 1071 data in 2024, with annual submission in June of 2025. Note - the proposed rule provides instruction for a partial year collection with the initial implementation of 1071 reporting requirements in 2024. Full year collection would likely begin in 2025 with annual submission in 2026.
Yes, RiskExec will be launching a new module called 1071 Small Business Lending in 2023 to help users prepare their 1071 data for submission.
Please reach out to Chris Gray at cgray@asurity.com to learn more about the pricing of RiskExec's 1071 Small Business Lending module.
1071 is a new submission requirement that is similar to HMDA. As such, users will be able to upload and import their 1071 data in flexible format, geocode, scrub, analyze, and prepare their 1071 data for submission. Because the variety of credit products and related systems for small business is broad, the RiskExec team anticipates more complex data ingest, analytic processes and reporting.
Yes, this module will be available for purchase in early 2023 as it is separate from our existing modules, with considerable additional scope and support.
If you are interested in learning more about RiskExec's 1071 Small Business Lending Module, please contact Chris Gray at cgray@asurity.com.
Sources: Consumer Financial Protection Bureau
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