Financial institutions that will be subject to the Small Business Lending Data Collection Rule (Section 1071) must implement and maintain a “firewall” …that prohibits certain employees and officers of covered financial institutions (and certain of their affiliates’ employees and officers) from accessing… restricted data collected from applicants. Restricted data includes the …applicant’s responses regarding the applicant’s minority-owned business status and women-owned business status, and its principal owners’ ethnicity, race, and sex.
Jerod took a deep dive into the Section 1071 firewall requirements during the August 1071 Membership Group meeting. Here is a little bit of what he had to say:
Published 2026/10/18