CFPB 1071 RULE: Checklist for Compliance Success By Paula King, Abrigo Executive Summary Commonly known as the CFPB 1071 Rule, upcoming requirements to be finalized in 2023 by the Consumer Financial Protection Bureau (CFPB) will represent the most significant effort of data collection and reporting for financial institutions in nearly 50 years. The checklist provides lenders with seven steps to prepare for compliance with this new rule. Introduction Section 1071 of the Dodd-Frank Act amended Regulation B - Equal Credit Opportunity Act (ECOA). On Sept. 1, 2021, the CFPB issued a proposed rule to require financial institutions and others to compile, maintain, and submit to the CFPB certain data points on applications for credit for small businesses, including those owned by women and minorities. While officially titled “Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B),” the proposed rule is often known as the CFPB’s 1071 Rule. The primary purposes of reporting this information are to: • Provide tracking of small business credits to enforce fair lending laws • Enable creditors to identify and support the business needs of women and other minorityowned small businesses within the community CFPB 1071 Deadline Ahead The final rule is expected by March 31, 2023, with compliance required 18 months after the publication of the final rule. While 18 months may seem like a long lead time, don’t let that timeframe lull you into inaction. This is a major effort of small business data collection and reporting not experienced since the Home Mortgage 12 NEBRASKA INDEPENDENT BANKER
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