WE ’ RE HERE TO HELP
ACTION STEPS
Every financial institution should determine the applicability of the final rule and , if necessary , the business lending application process and how to collect and report all the new data points . You will need to conduct staff training and implement system changes . Do not forget the ancillary final rule provisions beyond collecting and storing data :
1 . Establish and maintain procedures to identify and respond to signs of potential discouragement , including low response rates for applicant-provided data . This could be an area examiners key in on .
2 . Establish and maintain , unless an exception applies , a firewall so employees and officers are not able to access an applicant ’ s responses to the inquiries regarding the applicant ’ s owned business statuses and its principal owners ’ ethnicity , race and sex , if that employee or officer is involved in making any determination concerning the applicant ’ s covered application .
3 . Publish a statement on your website stating your small business lending data , as modified by the CFPB , are , or will be available , from the CFPB .
WE ’ RE HERE TO HELP
As you navigate through the complexity of the final regulation , Doeren Mayhew stands ready to assist with any questions you may have . Contact us today .
John Zasada , JD , CAMS - Shareholder zasada @ doeren . com 218.790.1086
7