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