Section 1071: Applicant-Provided Data
As you prepare to comply with Section 1071, your procedures will need to address how you will request, collect and record the applicable data. One area that you really want to focus on is the data designated by the regulation as “applicant-provided data”. This is the data that may or, in some cases will need to be, requested directly from the applicant. Your procedures must be “reasonably designed to obtain a response”. The rules state, A covered financial institution shall not discourage an applicant from responding to requests for applicant-provided data…and shall otherwise maintain procedures to collect such data at a time and in a manner that are reasonably designed to obtain a response. This includes ensuring that it is easy for the applicant to respond and that they are not discouraged from providing the information.
Published
2024/12/09
Jerod Moyer
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!