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The CFPB recently issued a Small Entity Compliance Guide (Guide) on the small business lending rule that implemented Section 1071 of the Dodd-Frank Act. WBK previously wrote about the small business loan rule here.
The Guide provides a detailed summary of the Small Business Lending Rule and uses examples to illustrate selected parts of the rule. Specifically, the Guide is organized into eight parts and provides details on the following topics: (i) the scope and coverage of the standard; (ii) the data points that covered financial institutions are required to compile, report, and maintain; (iii) the requirements of the rule for the collection and compilation of data; (iv) a prohibition on certain employees and officers of a covered financial institution or its affiliates from accessing certain demographic information obtained from small business applicants, also known as the “firewall” requirement; (v) record retention requirements; (vi) data reporting to the CFPB; (vii) the availability and disclosure of the data; and (viii) the effective and compliance dates associated with the rule. While the Guide is a useful tool, entities are reminded to also review the final rule.
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