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#2282536 - 03/23/23 02:55 PM ECOA Small Business Data Collection
Skyline Offline
Platinum Poster
Joined: Sep 2005
Posts: 590
Do we use the effective date to begin data collection (90 days after Federal Register publication) or compliance date (18 months after that same publication)?

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Lending Compliance
#2282537 - 03/23/23 02:59 PM Re: ECOA Small Business Data Collection Skyline
rlcarey Online
10K Club
Joined: Jul 2001
Posts: 81,310
Galveston, TX
It has not been published yet, has it? It will tell you in the final rule.
The opinions expressed here should not be construed to be those of my employer:

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#2282572 - 03/23/23 05:39 PM Re: ECOA Small Business Data Collection Skyline
Inherent_Risk Offline
Gold Star
Joined: Jan 2017
Posts: 486
Until it's final we can't know exactly, but it will be closer to 18 months (if it's 90 days to start collecting there will be a riot).

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#2282950 - 03/31/23 09:15 PM Re: ECOA Small Business Data Collection Skyline
Sheldon Hendrix Offline
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Sheldon Hendrix
Joined: Jun 2006
Posts: 1,170
Well I'm sure we're all aware it has been published, with staggered effective and reporting dates depending on covered transaction volumes.

Was kind of hoping the powers that be here on BOL might make a special forum under DODD-FRANK FINAL RULES DISCUSSIONS section for this topic. If there is one I'm overlooking, someone let me know!

What a time to be an external service provider (used to be one). We're all in this together!

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