In Part I of this two-part podcast, we examine the CFPB’s proposed rule implementing Sec. 1071 of the Dodd-Frank Act which would impose significant new data collection and reporting requirements on lenders in connection with credit applications made by women- or minority-owned small businesses. After reviewing the history of Sec. 1071 rulemaking (including the lawsuit that prompted the CFPB to act under a court-imposed deadline), we discuss the proposal’s key definitions and data collection requirements (including timing and related procedures and reuse of previously collected data).
Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by John Culhane, a partner in the firm’s Consumer Financial Services Group, Lori Sommerfield, Of Counsel in the Group, and Heather Klein, an associate in the Group.
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