After many fits and starts, whether from the courts, the new administration, or the CFPB itself, we finally have a new final rule to work with. The good news is many of the asks the industry has had with the CFPB have been answered, and in a good way. It’s now time to parse the requirements and figure out what we have to do (if you have to do anything at all, at least yet).
From changes in reporting thresholds and new exemptions to revised definitions of “small business loan” and revised data elements to report, there’s still a lot to do. The good news here is collection won’t be required until 2028 for everyone (no tiers anymore), but that’s not that far away. There’s also good news in that much of the implementation work small business lenders did in anticipation of the new rule won’t go to waste – we just have to revise what we have to do.
In this webinar we’ll go in-depth into the new rule and nail down precisely what you have to do, when you have to do it, and in what format. But our focus will not be a simple recitation of the proposed rule, but how to effectively develop and refine your implementation plan. We’ll review the many issues so you can methodically ensure your program is on track.
We’ll also talk about what this data means from a fair lending standpoint, including the (eventual) public nature of the information and some suggestions for fair lending analytics, as well as policy and procedure impacts. Join us for this in-depth discussion of the rule so you can best prepare for implementation, both operationally and technologically, and also culturally.
Use this extra time before implementation to make sure things are right.
