The CFPB just lately issued a compliance information for its ultimate rule implementing Part 1071 of the Dodd-Frank Act. Per Part 1071, the ultimate rule (issued on the finish of March) would require monetary establishments to gather and supply to the Bureau information on lending to small companies, outlined as an entity with gross income underneath $5 million in its final fiscal 12 months (lined by InfoBytes right here). The information: (i) features a detailed abstract of the ultimate rule’s necessities, together with information reporting deadlines; (ii) supplies complete data on the kinds of information monetary establishments want to gather and report on small enterprise lending purposes and selections; and (iii) contains parameters for lined establishments and lined originations. The information additional breaks down reportable information factors and explains the ultimate rule’s “firewall” provision, which states that workers and officers of a monetary establishment or its associates “concerned in making any willpower” on a reportable software are usually prohibited from accessing applicant demographic data regarding ethnicity, race, intercourse, and standing as a minority-owned, women-owned, or LGBTQI+-owned enterprise. The information specifies that sure exceptions might apply to conditions the place an worker concerned in decision-making should have entry to the information to satisfy their assigned job duties (e.g. a mortgage officer or mortgage processor). In these conditions, monetary establishments are required to supply discover to candidates that workers and officers concerned in decision-making might have entry to their demographic information.

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