Small Business LAR – 1071

TCA often helps financial institutions review commercial loans for Regulation B compliance, which includes handling adverse action loan applications. During these reviews, TCA sees numerous mistakes, such as: TCA – A Better Way!

At TCA, we’ve already been fielding calls from clients confused about gross revenue under 1071. It is a key factor when identifying small business loans for the count of originations for the prior two years. Under 1071, a small business is defined as one with a gross revenue of $5 million or less. Financial institutions

Application dates are sometimes a foreign concept in commercial lending. However, now that 1071 is a reality, commercial divisions everywhere will have asked themselves, “When do I have a completed application?” and perhaps the most important question of the day, “What will define my application date?” In commercial lending, it’s not as simple to determine

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

There is no doubt that the 1071 Small Business LAR Rule will change the way commercial lending departments operate. Compliance and Commercial Lending have not always gone hand in hand. Generally, there are lower compliance burdens for commercial purpose loans. As such, commercial lenders may be used to following strict guidelines and meeting regulatory requirements.

Establishing a 1071 Implementation Committee is essential for your institution to ensure Regulation 1071 compliance. Your committee’s first order of business is preparing a risk assessment and reviewing the regulation to determine its impact on your processes and procedures. It also manages the project, prepares progress reports for stakeholders, addresses problems like delays and lack

We all knew more guidance on 1071 Dodd-Frank on Small Business Data Collection was coming. On May 17, 2024, the Consumer Financial Protection Bureau (CFPB) announced an interim final rule extending the compliance dates for data collection and data reporting for financial institutions. The Rule requires financial institutions to collect and report small business lending

The Supreme Court has ruled on the constitutionality of the CFPB’s funding. I am somewhat surprised by the outcome and glad a decision was announced on May 16, 2024. A second Motion for Summary Judgement was filed by the TBA, Rio Bank, and the ABA, essentially saying that the Final Rule for 1071 “goes far