(As published in Dodd Frank Update, June 2025)
Jason Keller notes in a recent Consumer Bankers Association panel that the small business data collection requirements in New York—compared to those in the Consumer Financial Protection Bureau’s final rule implementing Sec. 1071 of the Dodd-Frank Act—share many similarities, with a key difference being that while implementation of the Bureau’s rule has been held up in federal court, the New York rule has been effective since 2023:
“In the state of New York, you still have to do 1071-like compliance,” Keller said. “This is a big deal from a data capture point of view, because now the business work that [compliance teams] have to do is going to be different for the state of New York. That’s because the state of New York’s rule contains about 99 percent of what the CFPB’s 1071 rule does and it’s in effect today.”
With state regulators stepping up their game on CRA and other matters, and federal banking regulators continuing to monitor CRA activity – albeit without the 2023 rule revisions – compliance teams should continue to have plenty of work ahead of them.
