As you likely know, the Section 1071 Rulemaking will present a substantial challenge for many financial institutions. We also know it’s difficult to get people excited about a final rule that hasn’t even been issued and isn’t expected to be issued until March 2023.
While we don’t want anyone losing sleep over Section 1071 (at least not yet), we’ve been saying for quite some time that you do need to start thinking through the small business data collection requirements (as proposed) and how they will impact your institution. Even before issuing a final rule, the CFPB is already looking ahead to implementation and will be hosting two sessions on “Technical Readiness.”
The first session will be conducted virtually on August 19, 2022, and an in-person event will also be held on September 15th. If there is enough interest, a virtual option may be added to the September session. Please note you must RSVP to attend either session.
It’s important to note that it appears these sessions will be geared more toward the system/software requirements, as the CFPB indicates the following individuals should attend:
“In-house technical staff” within financial institutions;
Core Processing Vendors;
Side Processors; and,
“Other third-party technology”
A sample draft Filing Instruction Guide (FIG) that was put together based on the proposal will be reviewed. The CFPB also notes it will solicit feedback on the best ways to build a system to receive 1071 data and work with those systems already in use.
