The CFPB not too long ago issued a Compact Entity Compliance Guide (Guide) regarding the tiny business enterprise lending rule that implemented Section 1071 of the Dodd-Frank Act. WBK previously wrote about the tiny business enterprise lending rule right here.
The Guide delivers a detailed summary of the tiny business enterprise lending rule, and utilizes examples to illustrate choose portions of the rule. Particularly, the Guide is organized in eight components and delivers detail on the following subjects: (i) the scope and coverage of the rule (ii) the information points that covered economic institutions are essential to compile, report, and preserve (iii) the rule’s specifications for collecting and compiling information (iv) the prohibition against specific personnel and officers of a covered economic institution or its affiliates accessing specific demographic information and facts obtained from tiny business enterprise applicants, also identified as the “firewall” requirement (v) the record retention specifications (vi) reporting information to the CFPB (vii) the availability and disclosure of information and (viii) the helpful and compliance dates linked with the rule. While the Guide is a useful tool, entities are reminded that they should really assessment the final rule as effectively.