An Even Deeper Dive into the CFPB’s Final Section 1071 Rule on Small Business Data Collection
On April 17, we held a 90-minute webinar in which we took a deep dive into the Consumer Financial Protection Bureau’s final rule to implement Section 1071 of the Dodd-Frank Act. Section 1071 amended the Equal Credit Opportunity Act to require financial institutions to collect and report certain data in connection with credit applications made by small businesses, including women-, minority- or LGBTQI+-owned small businesses. We expected there to be a high level of interest in the rule because it expands the reach of the CFPB’s enforcement jurisdiction to many more lenders. However, we did not anticipate that our webinar would be a “record breaker” with more attendees than any of our prior webinars or generate the high volume of questions that it did.
While we have responded to questions submitted by various individuals, we believe that all webinar attendees and those who were unable to attend could benefit from many of these questions and our responses to them. The questions and our responses address a wide range of challenging issues, such as when an institution must start collecting and reporting data, distinguishing business purpose and consumer purpose transactions, the rule’s exclusion of leases and other transactions, the rule’s application to indirect auto lenders, complying with the rule’s “firewall” requirement, the application of the “grace period,” and public disclosure of data. In this webinar, we will share these questions and our responses and also discuss information we have learned since our April webinar.
CLE Credits: This program is approved for 1.0 CLE credit in CA, NJ, & NY. Uniform Certificates of Attendance will also be provided for the purpose of seeking credit in other jurisdictions. Please note: CLE credit in the following states will not be available: NV and PA.
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