Answer:
“Section 1071” as it is being referred to is expected not later than Q1-2023. The following is speculation and depends on the CFPB and the industry’s ability to adapt to the new rules. Assuming the CFPB wants to start with an entire year that would require banks to meet implementation requirements in 2023 for a 2024 reporting period, or possibly 2025. But I have heard the CFPB wanted to get the final rule out by year end 2022 and that could make 2024 a possibility..
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