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FRB might extend compliance date

June 24, 2011
The Federal Reserve Board has proposed temporarily exempting motor vehicle dealers engaged in indirect (three-party) vehicle financing transactions from a new, comprehensive data collection and reporting requirement that is scheduled to take effect July 21.
 
Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 requires financial institutions, including dealers, to inquire into whether a credit applicant is a small business or a women-owned or minority-owned business and to maintain a record of responses to the inquiry that is separate from the credit application. If the applicant responds to the inquiry, the financial institution must then:
           
• compile and itemize eight fields of data related to the credit applicant and the credit requested,
• retain the data for a period of three years,
• submit the data to the federal government on an annual basis, and
• make it available to the public upon request.
           
Section 1071 imposes additional requirements, such as ensuring that the collected information does not contain any information that may identify a person connected with the business credit applicant.
           
Because dealers will require much additional direction from the government before they can be expected to carry out these duties, the FRB is considering extending the effective date of final regulations which explain those duties.
           
The Board will accept public comments on its proposal before issuing a final ruling.
 

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