Small Business LAR – 1071

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 5 What is an Application Date?

Application dates are sometimes a foreign concept in commercial lending. However, now that 1071 is a reality, commercial divisions everywhere will have asked themselves, “When do I have a completed application?” and perhaps the most important question of the day, “What will define my application date?” In commercial lending, it’s not as simple to determine

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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 3 Understanding the Flow of Commercial Lending

There is no doubt that the 1071 Small Business LAR Rule will change the way commercial lending departments operate. Compliance and Commercial Lending have not always gone hand in hand. Generally, there are lower compliance burdens for commercial purpose loans. As such, commercial lenders may be used to following strict guidelines and meeting regulatory requirements.

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1071 Preparation Guide | Article 2 Identifying Stakeholders, Forming A Committee

Establishing a 1071 Implementation Committee is essential for your institution to ensure Regulation 1071 compliance. Your committee’s first order of business is preparing a risk assessment and reviewing the regulation to determine its impact on your processes and procedures. It also manages the project, prepares progress reports for stakeholders, addresses problems like delays and lack

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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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CFPB Funding Mechanism Determined Valid

The Supreme Court released their decision in the Consumer Financial Protection Bureau v. Community Financial Services Assn. of America, Ltd. case, which was brought to challenge the funding of the CFPB as inconsistent with the Appropriations Clause. The challengers argued that this funding mechanism violated the appropriations clause, which provides that “no money shall be

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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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