Preparing for Section 1071
Abrigo
SEPTEMBER 14, 2022
In 2011, the CFPB interpreted Section 1071 to mean that obligations for financial institutions to collect, maintain, and submit data “do not arise until the [CFPB] issues implementing regulations and those regulations take effect.” So back in 2011, we understood the next logical step. Credit Risk Management. CRE Lending.
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