After more than ten years and extended litigation to compel rulemaking, on March 30, 2023, the Consumer Financial Protection Bureau (CFPB) issued the final rule which implements the small business lending data collection requirements set forth in section 1071 of the Dodd-Frank Act (Section 1071).  The final rule, together with the comments, is just under nine hundred pages.[1]  Broadly presented, the final rule can be broken down into a series of questions to be answered.  First, are the lender, the borrower and the transaction covered by the rule?  Second, what information must be collected and reported?  Third, how is the information reported?  Fourth, when does the rule take effect?

Robert Grbic has more than 30 years of commercial lending experience. He has been with the company and its predecessor since 2005, previously serving as senior executive vice president and chief credit officer where he was involved in creating a hands-on, best-practices credit culture, as well as helping the Company expand its client portfolio.

Before that, Grbic was managing director at MorrisAnderson & Associates ltd., a turnaround-consulting firm. He also co-founded MetSource Capital, LLC, a restructuring and corporate finance firm, working primarily with small- and medium-sized companies. In addition, Grbic has also served at GMAC Commercial Credit, LLC, BNY Financial Corp and Bankers Trust. He has served as an instructor for the Finance, Tax and Law Department at the NYU School of Continuing Education. Grbic holds master’s and bachelor’s degrees in Business Administration from Pace University.