The CFPB’s ultimate rule implementing Part 1071 requires monetary establishments to gather and report sure information in reference to credit score functions made by small companies, together with women-, minority- or LGBTQI+-owned small companies. On this episode, we reply to questions obtained from attendees of our April 2023 attendance-breaking webinar in regards to the ultimate rule. The problems our responses deal with embody: what’s a “lined transaction” and distinguishing enterprise/client goal transactions; figuring out the relevant See extra +
The CFPB’s ultimate rule implementing Part 1071 requires monetary establishments to gather and report sure information in reference to credit score functions made by small companies, together with women-, minority- or LGBTQI+-owned small companies. On this episode, we reply to questions obtained from attendees of our April 2023 attendance-breaking webinar in regards to the ultimate rule. The problems our responses deal with embody: what’s a “lined transaction” and distinguishing enterprise/client goal transactions; figuring out the relevant compliance date, making use of the “grace interval,” and pre-compliance date information assortment; which originations have to be reported, that are excluded, who has reporting obligations in a number of get together transactions equivalent to oblique auto loans, and figuring out who’s a small enterprise; reliance on broker-collected information and information assortment when small enterprise standing is unsure; complying with information segregation and “firewall” necessities; reporting points for securities-backed loans; CFPB identification/therapy of underperforming originators; and information to be publicly disclosed and CFPB strategy to information evaluation. We additionally talk about the preliminary injunction issued by a Texas federal courtroom staying the rule’s compliance dates for the plaintiffs solely and the way different entities topic to the rule have reacted.
Alan Kaplinsky, Senior Counsel in Ballard Spahr’s Shopper Monetary Providers Group, leads the dialogue joined by John Culhane and Richard Andreano, companions within the Group, and Loran Kilson and Kaley Schafer, associates within the Group. See much less –
