Significant Regulatory Changes Are About to Impact Your Training & Policy Management

Read the CU Times article here.

Here is a brief summary:

• Section 1071 (Small Business Data Collection Act):

  • Requires credit unions and other financial institutions to collect and report data on small business loan applications.
  • Applicable to institutions with at least 100 covered originations in the previous two calendar years.
  • Includes loans, lines of credit, credit cards, and merchant cash advances.
  • Institutions must maintain procedures for data collection and provide adequate training to staff.
  • Safe harbor provisions for initial demographic data collection errors.

• Section 1033 (Personal Financial Data Rights):

  • Mandates covered entities to provide consumers access to their financial data upon request.
  • Enforces consumer control over their financial data in line with open banking principles.
  • Applies to financial institutions under Regulation E and card issuers under Regulation Z.
  • Includes checking, savings, asset accounts, prepaid accounts, credit card accounts, and digital wallets.
  • Commercial or business accounts and certain loan accounts are exempt.
  • Six categories of required information include transaction details, account identity, and consumer reports.
  • Regulation to be effective 60 days after publication if finalized.

• Overall Impact:

  • Financial institutions must update training programs and policies to comply with new regulations.
  • Emphasis on ongoing education for employees to ensure regulatory standards are met.
  • Regulatory updates necessitate proactive adjustments to training and policy management systems.