I have recently been asked to develop a compliance program for the new CFPB 1071 rule which requires every creditor that originates 100 or more covered transactions to small businesses in the preceding years to report to the CFPB on a series of metrics.
Has anyone started doing this yet? If so, how are you going about it? Are you hiring external consultants or leveraging internal resources? Are you buying new software or adding new modules to existing software to ensure compliance?
As a credit union, we have been and continue to gear up for this. It helps that we already have a system for HMDA. Contact me if you would like to be put in touch with our person primarily responsible.
As a credit union, we have been and continue to gear up for this. It helps that we already have a system for HMDA. Contact me if you would like to be put in touch with our person primarily responsible.