When implementing and creating processes for the 1071 Small Business LAR Rule, determining when the institution will be subject to the collection and reporting requirements is vital.
The CFPB’s tiered implementation means we must first undertake a count to determine when the institution is subject to the collection and reporting of the covered data. The count is an important first step.
Article 1 in our series for 1071 implementation covers those reporting tiers.
The count is an important first step to implementation. The final rule provides three methods to determine if a Small Business loan should be counted; however, before making that determination, we need to first understand what is considered a “Small Business.”
TCA – A Better Way!
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