Small Business Regulatory Enforcement Fairness Act SBREFA (1071)

On September 1, 2021, the Consumer Financial Protection Bureau (CFPB) published its Summary of Proposed Rulemaking in regards to changes to the Small Business Regulatory Enforcement Fairness Act (SBREFA) as dictated under section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). Under the proposed changes, lenders will be required to compile, maintain, and submit the type and purpose of the loan, the census tract for the applicant's principal place of business, and the race, sex, and ethnicity of the principal owners of the business, along with a number of other data points.

RATA has reviewed the proposed rulemaking and found that this will coexist perfectly within Comply as a separate SBREFA component alongside CRA and HMDA, and believe that Comply can substantially aid in the collection, edit checking and submission of the final data points for SBREFA which will help minimize the financial impacts on lenders to meet these requirements. Once the finalized specifications are published, development will begin in earnest and as always, RATA will rise to the occasion and have the functionality available well before the submission of the data is required.

This new component will be available to all RATA clients and can be added to your existing RATA contracts with a simple order form when the product is ready. Feel free to call with any questions or comments.