Section 1071 Q&As post twenty five

To determine the size of the small business do we include the entire relationship or just the information for the individual loan?

It would be based on the GAR of the borrower and affiliates if borrower elects to provide that information (but it is not required, and lender may ignore affiliate GAR)

Do you know of any vendors who have started to implement 1071 into their software? 

The Rule was announced a little more than a month ago. It is not likely that software vendors have completed the programming necessary in that short time period. However, every loan software vendor will need to incorporate the Section 1071 provisions into their software.


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