With the CFPB seemingly being shut down, at least temporarily, we’ve been asked a lot about what this means for the Section 1071 Rule. First and foremost, we don’t anticipate that the 1071 requirements will go away completely. While stranger things have happened and we could be wrong, we feel it’s much more likely that the regulation will get rewritten. So, the requirements could look somewhat different in the future. For example, they might revisit some of the data fields that weren’t specified in the original law but were added by the CFPB when writing the regulation.
At this point, we feel it’s best to just stay the course. You may, however, want to use some caution as far as making any large investments with vendors until things shake out a bit more.
Click the link for some recent discussion on this topic:
Our 1071 Thought Leadership, Implementation & Planning Group is a great way to stay on top of all the developments and keep on track to implement the requirements.