Section 1071: Requesting & Collecting Data
The Section 1071 requirements will, in short, require institutions to collect and report certain data on covered small business credit applications. A key piece to this puzzle will be to determine how and when the data will be obtained, or the “time and manner” in which data is to be requested and collected.
While the Final Rule actually provides quite a bit of flexibility, there is a lot to consider in order to build a compliant and efficient process. Some examples include the various ways in which applications may be received; third parties that may be involved; and handling information that is subsequently updated and/or verified.
Institutions must have procedures “reasonably designed” to collect what the Final Rule refers to as “applicant-provided data”, including the ethnicity, race and sex of an applicant’s principal owners.
Published 2026/05/07
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!