The CFPB lately issued a Tiny Entity Compliance Guide (Guide) regarding the smaller company lending rule that implemented Section 1071 of the Dodd-Frank Act. WBK previously wrote about the smaller company lending rule right here.
The Guide supplies a detailed summary of the smaller company lending rule, and utilizes examples to illustrate pick portions of the rule. Especially, the Guide is organized in eight components and supplies detail on the following subjects: (i) the scope and coverage of the rule (ii) the information points that covered monetary institutions are needed to compile, report, and sustain (iii) the rule’s needs for collecting and compiling information (iv) the prohibition against specific workers and officers of a covered monetary institution or its affiliates accessing specific demographic facts obtained from smaller company applicants, also recognized as the “firewall” requirement (v) the record retention needs (vi) reporting information to the CFPB (vii) the availability and disclosure of information and (viii) the successful and compliance dates related with the rule. While the Guide is a useful tool, entities are reminded that they need to critique the final rule as properly.