Case Study: Small Business Lending/Rule 1071 Readiness

Big Picture

Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act mandates that financial institutions collect and report data about small business lending, particularly around gender, race, and ethnicity, to help ensure fair lending practices and to identify potential discrimination in small lending.  As a result, organizations will have to comply with this new regulation which will have wide-ranging implications across systems, processes, and data management practices to meet the reporting requirements.

Case Study - SBL 1071

Client Scenario

A large regional bank was taking proactive steps to prepare for the implementation of 1071 and sought expert guidance to evaluate the rule’s applicability to the organization and the bank’s readiness. The bank needed to determine if and when 1071 would be applicable, and assess their current data collection, processing, and reporting capabilities to determine gaps necessitating remediation. This led them to partner with Asurity Advisors.

Asurity Solution

Asurity Advisors provided expert guidance to support the bank in its tier determination analysis, helping the institution understand how 1071 would apply to its operations based on its small business lending volume, a critical step for understanding the scope and scale of the required compliance efforts.

To gain a deeper understanding of the bank’s current systems and processes, Asurity Advisors met with each of the bank’s business units to map their existing workflows. Through this comprehensive process mapping exercise, Asurity Advisors performed an assessment and provided a detailed breakdown of the various systems utilized by different business units. Additionally, Asurity Advisors conducted a thorough 1071 data field assessment, identifying potential gaps in the bank’s current ability to capture and manage the necessary data for 1071 compliance.

Asurity Advisors also facilitated the identification and evaluation of existing controls, compiled a comprehensive list of observations, and provided actionable recommendations designed to guide the bank toward achieving full compliance with 1071 while mitigating the risk of non-compliance.