CFPB INDICATES COMPLIANCE WITH SECTION 1071 OF DODD-FRANK NOT REQUIRED UNTIL IMPLEMENTING REGULATIONS ISSUED

The Consumer Financial Protection Bureau (“CFPB”) has posted a memorandum stating that compliance with Section 1071 of the Dodd-Frank Act is not required until the CPFB issues implementing regulations.

Section 1071 of the Dodd-Frank Act amends the Equal Credit Opportunity Act to require that financial institutions (broadly defined as “any partnership, company, corporation, association [incorporated or unincorporated], trust, estate, cooperative organization, or other entity that engages in any financial activity”) collect and report information concerning credit applications made by women or minority owned businesses and by small businesses. This Section would have become effective on the Act’s designated transfer date, July 21, 2011. However, in light of inquires the CPFB has received regarding the enforcement date of this Section and other issues, it has decided to delay enforcement of this Section until it can issue regulations. The CPFB intends to provide guidance regarding “appropriate procedures, information safeguards, and privacy protections.”

  • Mike Tomkies