2024 Small Business Loan Data: 1071

Small Business Loan Data: 1071

1071 is moving forward.  The CFPB has announced the new compliance dates for Section 1071 Small Business Loan Data! For some, this will mean collection begins next summer, which means regardless of your size, you need to be prepared to answer questions from your customers as the pot will begin to stir.  Join CBA as we partner with Sentry Advisors to provide insight as to what you need to be doing NOW to identify your threshold, the impact across HMDA and CRA, and best practices to increase compliance with not only 1071, but HMDA, CRA and other commercial lending compliance regulations! Sentry’s Leah Hamilton will hold a workshop session during the seminar to help you prepare.

SPEAKER: 
Leah Hamilton
Director of Education Services & Compliance Advisor
Sentry Advisors

The new Section 1071 - Small Business Loan Data regulatory requirements will require a significant amount of upfront work for compliance and business units alike – despite any delay in the effective dates.  During this full day session, we will work through the regulatory requirements, highlight key areas that will require implementing considerations and efforts now rather than later, and develop a simple commercial loan application to address not only the new 1071 requirements but also incorporate other regulatory requirements such as Regulation B, FCRA, Regulation GG and more.

We will highlight the U.S. Supreme Court’s decision impacting the 1071 final rule as it is expected to be handed down prior to this session.  However, regardless of any U.S. Supreme Court decision, the Dodd-Frank Act requires collection of certain minimum data that still will require regulatory implementation.  As such, any Court decision may only impact some but not all of the 1071 final rule.  Join us to get you on track for what’s to come so you can be proactive!

The following topics will be covered:

• Regulatory requirements under 1071 and its implementing regulation, Reg B (ECOA)
• Coverage, including 1071 vs. HMDA vs. CRA
• Current tiered compliance dates
• Key definitions
• Data to be collected
• Rules governing data collection
• Firewall requirements
• Reporting requirements
• Recordkeeping requirements
• Enforcement challenges and opportunities
• Suggestions, tips and ideas
• Update based on U.S. Supreme Court decision, if available
• Available resources
  
  

Commercial Loan Application Considerations:
Due to the numerous data collections triggered by Section 1071, it is more important than ever for financial institutions to consider implementing an application for commercial loan requests.  During this part of the day’s session, we will roll-up our sleeves and build a simple commercial loan application together to address and incorporate (as applicable):

• Regulation B (ECOA) requirements/prohibitions for applications
• Regulation B Appraisal Notice
• FCRA requirements for permissible purpose and consents (do’s and don’ts)
• Regulation GG Unlawful Internet Gambling notice
• USA PATRIOT Act Notice/Disclosure
• Guarantors vs. Co-borrowers

ABOUT OUT INSTRUCTOR: 
With nearly 30 years of experience in the financial services industry, Leah is known for her passion, energy, wit and ability to engage audiences and clients in BSA/AML, Lending, Deposits and Compliance Risk Management.  Throughout her career, banks, credit unions, FinTechs, and federal and state associations have engaged her for compliance advice and training at all levels: front line, compliance, audit, board and management, and state and federal examiners. Leah brings a common-sense approach to finding compliance solutions in plain-English. She also serves as a faculty member of the Southwest Graduate School of Banking where she teaches compliance essentials, advanced compliance and compliance for new board members.  She received her Juris Doctorate Degree from NIU College of Law and her Bachelor’s Degree from the University of Texas at Dallas.