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Regulatory reporting compliance is top of mind for all financial institutions – especially as the Dodd-Frank 1071 ruling was enacted in March 2023, requiring covered financial institutions to collect and report small business lending data to the CFPB. While the final ruling increased the minimum volume threshold and exempts all but the several hundred largest credit unions, similarities between 1071 and existing HMDA reporting requirements present increasingly difficult challenges.

For 1071, qualifying institutions must quickly begin to accumulate, sift through and properly report all relevant data, but it is easier said than done. Lenders must accurately collect more than 20 additional data points from all small businesses, increasing the amount of time needed for every lending opportunity. Manual verification is fraught with human error, necessitating frequent checks-and-balances, and information can easily slip through the cracks. Credit unions anticipate having to staff up significantly and create new and comprehensive processes to ensure 1071 compliance, similar to their experiences when rolling out HMDA reporting in the past decade.

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