News & Analysis as of

Lenders Data Collection Financial Institutions

Orrick, Herrington & Sutcliffe LLP

CFPB publishes 2024 HMDA Modified Loan Application Register data

On March 31, the CFPB announced it published the 2024 HMDA Modified Loan Application Register data on the FFIEC’s HMDA Platform. The data, sourced from nearly 5,000 HMDA filers, included loan-level information to assess...more

Stinson LLP

An Uncertain Future for CFPB's Section 1071 Rule Regarding Small Business Lending Data

Stinson LLP on

In a pivotal development, the U.S Court of Appeals for the Fifth Circuit has stayed enforcement of the Consumer Financial Protection Bureau’s (CFPB) Small Business Lending Rule — also known as Section 1071 of the Dodd-Frank...more

Troutman Pepper Locke

Compliance Deadlines for the 1071 Rule are Tolled — But for an Unspecified Period of Time — Amid Legislative Efforts to Repeal the...

Troutman Pepper Locke on

On Friday, the U.S. Court of Appeals for the Fifth Circuit ordered the tolling of compliance deadlines for the Consumer Financial Protection Bureau’s (CFPB or Bureau) Small Business Lending Data Collection final rule under...more

Troutman Pepper Locke

Texas Federal District Court Rejects All Administrative Procedure Act Challenges to CFPB’s Section 1071 Final Rule

Troutman Pepper Locke on

Monday, the U.S. District Court for the Southern District of Texas granted the Consumer Financial Protection Bureau’s (CFPB or Bureau) motion for summary judgment on all Administrative Procedure Act (APA) challenges brought...more

Ballard Spahr LLP

Consumer groups show support of CFPB’s Auto Finance Data Pilot and urge the Bureau to expand its data collection

Ballard Spahr LLP on

In February 2023, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) announced an auto finance data pilot, where it ordered nine large auto lenders to provide information about their auto lending portfolios....more

GeoDataVision

Should the CFPB Reconsider the Implementation Dates for Section 1071 Data Collection?

GeoDataVision on

The recent Supreme Court ruling that upheld the constitutionality of the Consumer Financial Protection Bureau’s funding resulted in the Bureau announcing the new effective dates for banks to begin collecting their CRA...more

Ballard Spahr LLP

The Dilemma Facing Lenders Subject to the 1071 Small Business Data Collection and Reporting Rule

Ballard Spahr LLP on

We recently reported that a federal district court in Kentucky enjoined the CFPB from implementing the small business data collection and reporting rule, also referred to as the 1071 rule based on the Dodd-Frank section...more

King & Spalding

CFPB's New Small Business Data Collection Rule

King & Spalding on

A recent rule (12 CFR Part 1002, the “Rule”) issued in final form by the Consumer Financial Protection Bureau (the “CFPB”) earlier this year imposes a host of data collection and reporting obligations on lenders to small...more

Cadwalader, Wickersham & Taft LLP

Small Business Lenders Subject to New CFPB Data Reporting Rule

Resulting from a lawsuit by the California Reinvestment Coalition against the Consumer Financial Protection Bureau (“CFPB”) in 2019 for its failure to promulgate a small business lending data rule in compliance with the...more

Buchalter

CFPB’s Small Business Lending Data Collection Rule Increases Operational Burdens and Regulatory Risk for Lending to Small...

Buchalter on

On March 30, 2023, the Consumer Financial Protection Bureau (CFPB) issued the long-awaited final version of its rules on Small Business Lending under the Equal Credit Opportunity Act. The new rule imposes significant burdens...more

Moritt Hock & Hamroff LLP

Q&A On Preparing Now For 1071 – Brett Garver Answers Key Questions, Notes Heavier Burden On Smaller Lenders

Amid concerns about Section 1071’s potential impact on the secured lending and equipment finance industries, Brett Garver answers key questions about the new requirements and their implementation timeline. He is a partner...more

Davis Wright Tremaine LLP

CFPB's Small Business Lending Data Collection Rulemaking

Last month, the Consumer Financial Protection Bureau (CFPB) issued a long-anticipated proposed rule (published in the Federal Register on October 8, 2021) requiring regulated financial institutions to collect and report small...more

Bradley Arant Boult Cummings LLP

Ready or Not, Section 1071 is Coming: The Upcoming Implementation of Dodd-Frank’s Women and Minority-Owned and Small Business...

As part of the 2010 Dodd-Frank Act, Congress enacted Section 1071, which amended the Equal Credit Opportunity Act to mandate certain reporting requirements for lenders making business loans. The act aims to “facilitate...more

Bradley Arant Boult Cummings LLP

In the Wake of Equifax: What Auto Dealers Need to Know About Data Privacy

Following the recent Equifax data breach wherein millions of consumers’ private information may have been compromised, it is increasingly clear that consumer-interfacing businesses need to, and in some cases are required to,...more

Ballard Spahr LLP

84 House members urge expedited CFPB action on small business lending data collection rules

Ballard Spahr LLP on

84 House members recently wrote to the CFPB to urge it to expedite rulemaking to implement the small business lending data requirements of Dodd-Frank Section 1071. Section 1071 amended the ECOA to require financial...more

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