Margaret Dolinger

1071 Preparation Guide | Article 7 1071 Brings New Mandates for Commercial Lending and Adverse Action Reporting

TCA often helps financial institutions review commercial loans for Regulation B compliance, which includes handling adverse action loan applications. During these reviews, TCA sees numerous mistakes, such as: TCA – A Better Way!

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1071 Preparation Guide | Article 6 Gross Revenue – One of the Identifiers of Small Businesses

At TCA, we’ve already been fielding calls from clients confused about gross revenue under 1071. It is a key factor when identifying small business loans for the count of originations for the prior two years. Under 1071, a small business is defined as one with a gross revenue of $5 million or less. Financial institutions

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1071 Preparation Guide | Article 4 Identifying and Counting Covered Transactions

When implementing and creating processes for the 1071 Small Business LAR Rule, determining when the institution will be subject to the collection and reporting requirements is vital. The CFPB’s tiered implementation means we must first undertake a count to determine when the institution is subject to the collection and reporting of the covered data. The

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1071 Preparation Guide – Article 1 Getting Started and Best Practices

We all knew more guidance on 1071 Dodd-Frank on Small Business Data Collection was coming. On May 17, 2024, the Consumer Financial Protection Bureau (CFPB) announced an interim final rule extending the compliance dates for data collection and data reporting for financial institutions. The Rule requires financial institutions to collect and report small business lending

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charts and data

Mitigate Risk: Understand Your Lending Patterns

Examiners are more carefully scrutinizing banks’ lending penetration in low- and moderate-income census tracts for CRA and in substantially minority census tracts for Fair Lending in banks’ designated assessment areas. Examiners also expect banks to demonstrate a thorough understanding of their lending patterns. For example, they analyze HMDA loan data and Small Business/Small Farm loan

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Fair Lending

Stay on the Right Side of Fair Lending: 2023’s Top 5 FAQs

Fair Lending remains a hot topic with regulators and special interest groups. During 2023, our clients experienced heightened scrutiny around identifying patterns of disparity that could result in discrimination allegations and enforcement actions. Review the five key issues clients have faced and consider evaluating them at your institution. TCA – A Better Way!

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small business loan

Small Business Data Collection – Are You Having the Conversation?

By Margaret Dolinger, CRCM 1071 Dodd Frank requires financial institutions to collect data on small business loans and record them on a Small Business Lending Application Register. The Consumer Financial Protection Bureau (CFPB) issued a Proposed Rule on October 8, 2021, regarding the covered institutions and covered transaction pursuant to proposed Regulation B 1002.101 –

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