Answer:
It is the equivalent of the HMDA LAR for small business loans. With 21 fields to be completed, the data will be targeted to understanding your track record for small business lending. You’ll have information on race, ethnicity, gender, marital status, and more after you define if it is a small business to start with. If you have agonized over HMDA rules and definitions, this will be part 2. Staff will require training, and systems will require modifications and this all means testing and tweaking. A year may not be long enough.
Learn more about Andy Zavoina’s Annual LENDING Compliance Recap webinar.
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