Posted By: Skyline
ECOA Small Business Data Collection - 03/23/23 02:55 PM
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)?
Posted By: rlcarey
Re: ECOA Small Business Data Collection - 03/23/23 02:59 PM
It has not been published yet, has it? It will tell you in the final rule.
Posted By: Inherent_Risk
Re: ECOA Small Business Data Collection - 03/23/23 05:39 PM
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).
Posted By: Sheldon Hendrix
Re: ECOA Small Business Data Collection - 03/31/23 09:15 PM
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!