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On March 30, 2023, the Consumer Financial Protection Bureau (CFPB) issued the small business lending rule (final rule), which implements the small business lending data collection requirements set forth in section 1071 of the Dodd-Frank Act (Section 1071). This new rule requires those subject to it to collect and report certain information related to the loans they originate to small businesses, including those that are minority-owned or women-owned.
The challenge with this new rule, of course, will be to figure out how to implement the rule. Therefore, financial institutions will want to create some sort of implementation action plan to assist with this major project.
We created a sample implementation plan that can be used to assist financial institutions with implementing the requirements of section 1071 of the Dodd-Frank Act. The implementation plan, which can be downloaded below for free, is a sample only, and should not be viewed as everything a financial institution needs to do in order to comply with the requirements of the CFPB’s final rule. Each financial institution will need to determine the appropriate steps that apply to their unique organization. The steps outlined in the sample plan are for consideration only, and not considered legal advice. We are not attorneys and this is not legal advice - seek legal counsel.
