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Section 1071 Q&As post nine

Section 1071 does not contain any reference to a mandatory resubmission of Section 1071 if the error rate exceeds a specific threshold. Is there a mandatory resubmission standard of a HMDA LAR when a filer exceeds a specific error rate? No, a Bureau attorney in response to this question submitted by GeoDataVision explicitly stated to Len […]

Section 1071 Q&As post eight

Our bank has a subsidiary for some commercial financing such as equipment small ticket loans, floor plan financing, and asset-based lending. I know we need to file their loans on a separate register from the bank. Our question is do we combine the subsidiary and bank loans to determine when we must begin reporting or […]

Section 1071 Q&As post seven

Now that the Section 1071 rule is final, should we still be doing CRA Small Business as we do currently until we must begin the 1071 small business data collection based on the tier applicable to our loan volume? The OCC, the FDIC and the FRB in their 2022 notice of proposed rulemaking regarding CRA […]

Section 1071 Q&As post six

For HMDA loans that are also reportable as CRA CD reportable loans now, can we still report them as a CRA CD loan? And if yes, will that change based on the compliance date tier? Please explain. Regarding HMDAa reportable loans that are also qualified as community development, i.e. multi-family, affordable housing, those will continue […]

Section 1071 Q&As post five

Can you elaborate on what may be meant or intended by “feasibility” in relation to the firewall requirement? If I am reading the preamble and regulation correctly, it appears that feasibility really has more to do with job duties of employees instead of potential software/tech limitations of the institution. For us specifically, all of our […]

Section 1071 Q&As post four

I just want to confirm that all HMDA reportable transactions are excluded, even if we are not required to report them. We are exempt from open-end HMDA reporting. If I read the preamble correctly, those loans would still be exempt from 1071, correct? Any transactions reported under HMDA would not be reported under Section 1071. […]

Section 1071 Q&As post three

In the preamble, there is discussion on letters of credit on page 207. We create a note with our letters of credit. The note works like a closed-end line of credit and is only advanced if a claim is made on the letter of credit. The preamble letters of credit not being credit under commentary […]

Section 1071 Q&A post two

It seems that a banker will need to determine if the loan they are taking an application for is a HMDA loan, a CRA loan or Section 1071 loan. It is possible that a loan will be reportable for CRA and not Section 1071. Is there any safe harbor if a banker thought it was […]

Section 1071 Q&As post one

How can you report GAR as ‘not provided’ if you need to know this number in order to determine if it is reportable for Section 1071? It is my understanding that you do not have to verify GAR, so if a borrower tells you about $3M, then wouldn’t that be the amount to report instead […]

Free Small Entity Compliance Guide

The document is a Small Entity Compliance Guide for the Consumer Financial Protection Bureau's Small Business Lending Rule, which requires financial institutions to compile and report certain data regarding business credit applications to the CFPB. The guide provides examples of how the rule applies to different scenarios, such as online and in-person applications, and outlines […]

Section 1071 Q&A Week Two

Now that the Section 1071 rule is final, should we still be doing CRA Small Business as we do currently until we must begin the 1071 small business data collection based on the tier applicable to our loan volume? The OCC, the FDIC and the FRB in their 2022 notice of proposed rulemaking regarding CRA […]

Section 1071 Q&A Week One

We know that loans will be reportable for both CRA and 1071. What if we collect DemographicInformation and the loan ends up being reportable for CRA? Being reportable for CRA does notdisqualify a covered transaction from being reported under 1071. The PDI would be reportedunder the obligation imposed by 1071. Which Data Points are interpreted […]

Free up-to-date SBA Size Standards book from GeoDataVision

It is important for you to be aware that the term "small business," as outlined in Section 1071, specifically refers to the Small Business Administration (SBA) Regulations Part 121. In order to comply with the Section 1071 and to better understand the classification of a small business, it is essential to consult the updated Part […]

Free Webinar: Comprehensive review of Section 1071 Rule

Presented by GeoDataVision in partnership with M&M Consulting Brace yourselves! On March 30th, the CFPB unleashed the long-awaited Dodd-Frank Section 1071 Rule, and it's about to shake the finance world to its core. Thought the CRA data file was a migraine-inducing burden? Section 1071's reporting requirements will make you beg for mercy. With a jaw-dropping […]

Is a Big Fight with Bank Regulators Looming?

On February 13, the ABA Banking Journal bore a headline, "Nichols: ABA won't 'sit idly by', if regulators overstep their authority". The article went on to cite examples of rule making and regulatory changes "that will do more harm than good." In particular, the article identified the FDIC's plan to raise assessment fees and the […]

Meaningful and Practical Climate Risk Analysis for Banks – The Climate Risks Banks Face Today

We all know that Climate-Related Risk regulations are in the process. The prudential bank regulators are not waiting for lawmakers to legislate climate risk law, they are actively drafting "guidance" and will be evaluating climate risk exposure as a "Safety and Soundness" issue. It's not yet official, but regulatory requirements are imminent. Already as exams […]

“Figures don’t lie” but do regulators figure? Simpson’s Paradox says so

In emails in recent months we've warned bankers about the extremely aggressive enforcement of anti-redlining policies. This is becoming more and more obvious every day as more banks get threatened with referral to the DOJ. The word is the DOJ is now approaching a record backlog of potential redlining cases. What we find particularly troublesome […]

2021 reported Community Development and Consortium Lending for the entire country

One of the most important CRA responsibilities for Intermediate-Small Banks and Large Banks is "Community Development Lending". But while Community Development Lending is critically important, there is very little information available about the Community Development Loan Market. GeoDataVision has captured all the 2021 reported Community Development and Consortium Lending for the entire country and has […]

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