I would appreciate input from anyone:

(1) How is your bank handling the application process to be sure and collect all the data?
(2) If you will be using a loan origination software that includes the application process, what software or vendor to you plan to use?
(3) Is there any bank that plans on a manual process of collecting the data points, if so, do you have a data collection worksheet you can share?

We are searching for a software that can be used by the lender during the loan application process that will collect all the data points during the application process, store the data, and then format the data (once scrubbed) into a file to upload to the CFPB. We have looked at one vendor, and the price tag is staggering.

Thanks in advance!

Bump .....

Data collection is at least 2 years away, depending on when the Supreme Court rules on the CFPB funding structure. That and the possibility of different leadership at the CFPB could make the rule look a lot different by the time it's implemented. We are making incremental changes with our commercial lenders so it won't be a massive change when collection starts, but for the most part, we are in a holding pattern.

I applaud your efforts to get ahead of things, but most software companies I've talked to just have a basic shell built and will make the necessary updates as the rule gets closer to implementation.

Thank you for your input. I think we are basically in the same holding pattern as your FI, but I wanted to see if anyone has started the process of trying to be prepared for the implementation. Thanks again!

We are preparing to perform the review of 2022/2023 loans next month, but I'm wondering if this might change. I know that the CFPB has agreed to delay implementation as a result of the rule as a result of the lawsuit/injunction. Has anything been said about this?

The courts have placed a stay on the implementation of 1071 until the SC decides whether the funding structure of the CFPB is constitutional. Additionally, the implementation date of the rule will be delayed for the period that the rule is stayed. So if the SC doesn't rule until the end of their term in June, the implementation dates will be delayed by about 8 months.

Yes, that part I know. I was just wondering if the years that we consider for determining coverage might change.

The small entity guide (section 9.1) uses 2022 and 2023 origination totals for all tiers, so I don't think the delay in the implementation would automatically change the years considered. However, with a 8+ month delay in the implementation dates, I wouldn't be surprised if they change it to 2023 and 2024. We'll just have to wait and see...