CFPB Releases Outline of Proposals Under Consideration to Implement Small-Business Lending Data Collection Requirements

The outline provides insight into the data points that may be collected, including mandatory data points from Section 1071.

Compliance9/22/2020

The Consumer Financial Protection Bureau released its Outline of Proposals Under Consideration to implement the Dodd-Frank Act Section 1071 requirement to collect small business lending data.

Section 1071 requires financial institutions to collect certain data regarding applications for credit for women-owned, minority-owned, and small businesses, and to report that data to the CFPB on an annual basis. The Outline describes proposals that the CFPB is considering to implement Section 1071 along with the relevant law, the regulatory process, and an economic analysis of the potential impacts of the proposals on directly affected small entities.

The outline also provides insight into the data points that may be collected. The mandatory data points from 1071 include:

  • whether the applicant is a women-owned, minority-owned, and/or small business
  • application/loan number
  • application date
  • loan/credit type
  • loan/credit purpose
  • credit amount/limit applied for
  • credit amount/limit approved
  • type of action taken
  • action taken date
  • census tract (principal place of business)
  • gross annual revenue
  • race, sex, and ethnicity of the applicant’s principal owners
Question of the Week

Q. We have a member asking if it is permissible for them to store cash in their safe deposit box. We thought there was a rule against this but cannot locate one. Is it permissible for members to keep cash in their safe deposit boxes?

A. There are no regulations which prohibit the deposit of cash in a safe deposit box. In fact, the credit union should not attempt to monitor what members place in their safe deposit boxes, other than to alert members to the types of objects which must not be placed in boxes such as explosives, toxic materials, or other items restricted according to the terms of the contract.

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