SFNet has learned the final regulations pertaining to CFPB Section 1071 of Dodd-Frank, which could prove to be unduly burdensome to the vast majority of small and mid-sized finance companies that provide credit to small businesses, are expected to be issued on or before March 2023. Note that while factoring was previously exempted, we remain concerned that it could change in the final regulations.

For a detailed analysis, published in 2021, please see https://www.sfnet.com/home/industry-data-publications/the-secured-lender/magazine/tsl-article-detail/advocacy-alert-cfpb-section-1071-rule-could-place-burden-on-financial-institutions-action-required.

Comment letters: https://www.sfnet.com/docs/default-source/tsl-tslexpress/sfnet_commentletter_cfpb_1071_dec2021.pdf?sfvrsn=f2c7be6b_2
https://www.sfnet.com/docs/default-source/tsl-tslexpress/sfnet_cfpb_1071_comment-letter_dec10.pdf?sfvrsn=a0bb1983_2

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