Pub. 2 2023 Issue 4

Scan the QR code to access these resources. As the agency develops additional resources related to this rule, we can expect these to become available on this webpage. https://www.consumerfinance.gov/compliance/complianceresources/small-business-lending-resources/small-businesslending-collection-and-reporting-requirements/ To emphasize financial institutions’ obligations to collect this important data, the CFPB is also issuing a policy statement noting that it intends to focus its supervisory and enforcement activities in connection with the new rule on ensuring that lenders do not discourage small business loan applicants from providing responsive data, including responses to the requests to provide demographic information about their ownership. This policy statement is available by scanning the QR code. https://files.consumerfinance.gov/f/documents/cfpb_1071enforcement-policy-statement.pdf Implementation Note It is possible that the implementation schedule spelled out in the final rule (discussed above) will be delayed. A lawsuit has been filed, petitioning the court to push the implementation dates back to allow more time for financial institutions to develop their compliance programs for this rule. So, the expected schedule may be delayed, or may not be. One thing to keep in mind is that, even if the implementation dates are pushed back, they will eventually arrive. Therefore, all financial institutions that are active in small business lending should proceed with their planning and implementation process to be ready to comply when the rule does become effective for their institution.  vCISO for audit coordination and more….  Penetration tests  Vulnerability scans Cybersecurity tailored to community banks, because it was created by community bankers! 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 NEBRASKA INDEPENDENT BANKER 15

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