In Part II of this two-part podcast, we continue our examination of 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 small businesses, including women- or minority-owned small businesses. We discuss the “firewall provision” restricting employee access to data, the proposal’s intersection with HMDA reporting requirements, the likely timeline for issuance of a final rule and compliance deadlines, the outlook for CFPB supervision and enforcement of the final rule, operational considerations in preparing for implementation, and fair lending risk management implications and mitigants.
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, Heather Klein, an associate in the Group, and Richard Andreano, a partner in the firm’s Mortgage Banking Group.
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