Added on September 12, 2023
As announced previously, RATA is in the process of adding a new component to Comply 23 for Small Business Lending (SBL 1071). The SBL component will be very similar to the current HMDA/CRA components, as you can see from the screenshots below, and will be made available to all RATA customers to explore and test at no charge through June 2024. It will be released in phases to allow reasonable development and quality assurance time for our staff, as well as allow customers to begin testing, when they are ready. The Fall release will contain the basics for importing, data processing, and phase 1 of the edit checks. The edit checks are constantly evolving and usually change up until submission time. Everything but the actual submission should be contained in our Fall release. Submission capabilities will be added closer to submission dates for clients that purchase the new component.
You can order the product at any time, and will only begin paying for the year you need to officially begin collecting data for submission. In the meantime, you can continue to use and test the software at no charge. So if you are a large submitter that needs to collect the 2024 data you will pay for the full 2024 year, and so on. RATA will not be pro-rating the component on any volume categories.
The CFPB has taken a phased approach to the implementation of this new rule in that larger lenders are required to collect and report the data earlier than smaller lenders. Below are the guidelines:
|Annual Number of Originated Small Business Loans||Data Collection Start Date|
|At least 2,500||October 1, 2024|
|At least 500||April 1, 2025|
|At least 100||January 1, 2026|
We previously sent an inquiry to the CFPB regarding inconsistencies we noticed, some of which have been resolved. Below are our questions, their responses in italics, and the resolution (if applicable) in bold:
If you decide to move forward with the Comply SBL component, please contact Angela at als@RATAassociates.com to get the order form completed for your institution. We will continue to update you if we learn anything new. If you have any questions or comments feel free to contact us at firstname.lastname@example.org or 407-831-7282.
On March 30, 2023, the CFPB released the finalized rule to create the new data set on Small Business Lending (SBL) in America. Required institutions that originate at least 2,500 small business loans annually will be required to collect this data starting October 1, 2024. For smaller required lenders originating 500 loans or 100 loans annually, the dates to start collecting are April 1, 2025 and January 1, 2026, respectively.
RATA is currently reviewing the specifications and will be offering a new component in Comply to fulfill this rule. The new component will have similar functionality to the current HMDA and CRA components, and will be released in phases to allow reasonable time for development, allowing customers to become acquainted with the component and begin testing if they are so inclined. We should have the basics for data collection and importing contained in our fall release (September/October timeframe), then the edits and submission functionality shortly afterward.
Understandably there are differences between the SBL data collection versus HMDA and CRA, notably:
To simply explain the difference between SBL and CRA: SBL data concerns any size of loan to a small business, whereas CRA data concerns small loans to any size of business or farm. We expect that there could be some crossover where a loan will meet both SBL and CRA requirements, and in that case, will need to be reported/submitted in each component separately.
If you need a price quote for this new component for budget purposes, please send an email to email@example.com or call 407-831-7282 Ext. 200.
We will continue to update you if we learn anything new. If you have any questions or comments feel free to contact us at firstname.lastname@example.org or 407-831-7282.