currently and what change management will be required to implement these changes correctly and in a timely manner? • Has the bank established relationships with any vendors? Do the modules or other software offered need to be tailored to meet the bank’s needs? • What will the institution be employing for data integrity purposes? • What does a tailored project implementation plan look like for my institution? Other Resources In addition to the Final Rule itself, the CFPB published a bevy of other accompanying materials. One is a Fact Sheet, which outlines the history of the Section 1071 rulemaking and the various policy objectives driving it. Another is a Policy Statement which indicates “… that the CFPB intends to focus its supervisory and enforcement activities … on ensuring that covered lenders do not discourage small business loan applicants from providing responsive data, including … ECOA-mandated demographic data requests…” The CFPB also published a Filing Instructions Guide, which provides an overview of the filing process, instructions for what to enter in each data field, validation requirements that must be met before the register can be filed and additional resources to assist with inquiries. A Data Points Chart provides a visual guide to the various data point fields and their respective regulatory references, along with a brief description and filing instructions for each. An Executive Summary lays out an overview of the main facets of the Final Rule. Compliance Alliance will be publishing its own summary of the Final Rule very soon. Finally, a Key Dates chart provides a visual representation of the three compliance tiers and their respective mandatory compliance collection and reporting dates. Note that there are some additional tools on the CFPB’s resources page, and more may be added in the future. We’re Here to Help! It goes without saying that this is just an extremely brief overview of all the Final Rule entails. As you approach your compliance date, or just work to determine whether your institution may be covered at all, we’re here to help! Feel free to reach out to our Compliance Hotline by chat, email, or phone and one of our advisors will be happy to walk through your questions with you. www.bccadvisers.com WE VALUE BANKS. Business valuation for... ▪ Gifting and stock transfers ▪ Buy/sell agreements ▪ ESOP administration ▪ Estate settlement ▪ Stock offerings ▪ SBA 7(a) loans Lindy Ireland lindy@bccadvisers.com 434.333.6814 Now in Central Virginia! 21 The CommunityBanker
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