Other considerations important for financial institutions as they implement the CFPB 1071 Rule include whether to: • Standardize small business lending loan originations, pricing, and fee structures • Develop an objective small business loan pricing model to mitigate unintentional disparate treatment resulting from lender subjectivity in interest rate, fee, and pricing structure • Automate the reporting of small business loan pricing exceptions to policy to be proactive in making future adjustments Conclusion In a recent survey of financial institution executives, the final 1071 rule was the top regulatory compliance concern — outranking BSA/AML rules, beneficial ownership requirements, and CECL obligations. With Community Reinvestment Act reform also expected to increase data collection and reporting requirements for some financial institutions, it’s prudent to plan early for the CFPB 1071 changes. Working with dedicated third-party risk management consultants or advisors is a way to ensure compliance with CFPB 1071 while minimizing institutional disruption. 100 South Phillips Avenue, Sioux Falls (605) 335-5112 advantage-network.com MORE OPTIONS FOR YOUR CARDHOLDERS Why source your debit card production with The Advantage Network? So you can receive access to cutting-edge technology, quick turnaround, and personal assistance — because your cardholders deserve the best, and so do you. • Instant Issuance • Contactless cards • Customize Your Card program • Surcharge-free ATMs worldwide ASSURANCE / TAX / ADVISORY FORVIS is a trademark of FORVIS, LLP, registration of which is pending with the U.S. Patent and Trademark Office. FORward VISion counts Our vision is helping make yours a reality. Whether you’re looking to stay compliant, manage risk, or grow strategically, our forward-thinking professionals can help you prepare for what’s next. forvis.com/financial-services FOR unmatched industry insight, VISion matters NICBONLINE.COM 15
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