ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Uncategorized

Compliance question of the month: How can banks estimate GAR to determine their tier for data collection purposes under the 1071?

August 17, 2023
Reading Time: 1 min read

My bank will be reporting small-business lending data under the Equal Credit Opportunity Act (as required by the §1071 rule) and is trying to determine which tier the bank falls under for data collection and reporting purposes. However, the bank has not routinely collected gross annual revenue (GAR) from its small-business borrowers to be able to determine whether the bank meets the threshold for reporting of 100 originated covered credit transactions in each of the two preceding calendar years.

Q Is there a suggested method for determining the GAR for 2022 and 2023?

AThe bank may use “any reasonable method to estimate its originations to small businesses for either or both of the calendar years 2022 and 2023″ which could include any of the following options.

The bank may:

  • Ask every applicant of a covered credit transaction approved between October 1 through Dec. 31, 2023 to self-report whether its GAR for the preceding fiscal year was $5 million or less;
  • Assume that every covered credit transaction it originates for business customers in calendar years 2022 and/or 2023 is extended to a small business;
  • Annualize the number of its covered credit transactions from Oct. 1 through Dec. 31, 2023 by quadrupling the originations for this period and apply the annualized number of covered originations to both calendar years 2022 and 2023 or to either 2022 or 2023.

See comment 5 to §1002.114(c) and the Consumer Financial Protection Bureau’s small business lending rule FAQs – Institutional coverage FAQ #14.

For more information, contact ABA’s Rhonda Castaneda.
Please note that this section is not a substitute for professional legal advice.

Tags: ComplianceECOAFair lendingSection 1071
ShareTweetPin

Related Posts

Supreme Court upholds government authority to dismiss False Claims Act cases

Eighth Circuit affirms vacatur of Regulation II

Uncategorized
November 3, 2026

While the Eighth Circuit vacated Reg. II, the Sixth Circuit has yet to issue its decision in Linney’s Pizza. There, a Kentucky federal court granted summary judgment to the Fed and rejected the merchant’s challenge to Reg. II.

U.S. Supreme Court vacates Ninth Circuit preemption decision

U.S. Supreme Court to review discovery ruling in DOGE FOIA lawsuit

Uncategorized
November 3, 2026

The U.S. Supreme Court agreed to review a D.C. Circuit ruling allowing discovery to determine whether the U.S. DOGE Service qualifies as an agency subject to the Freedom of Information Act.

Minnesota dismisses cash-sweep program lawsuit against U.S. Bancorp

Southern District of New York rules Merrill Lynch but not BofA must face cash sweep lawsuit

Uncategorized
November 3, 2026

A New York federal court dismissed a class action against Bank of America Corporation, Bank of America N.A. and Managed Account Advisors LLC but allowed claims against Merrill Lynch to proceed in a lawsuit alleging unreasonably low interest...

Former CFPB enforcement attorneys file class action challenging Unlock’s home equity agreements

Former CFPB enforcement attorneys file class action challenging Unlock’s home equity agreements

Uncategorized
November 3, 2026

Colorado homeowner Sheila Johnsen filed a class action against Unlock Partnership Solutions alleging that they disguised mortgage loans as home equity agreements to evade lending laws, charge excessive interest and impose unfair contract terms.

New York district court denies Terraform Labs’ motion to dismiss, declines to follow Ripple ruling

Northern District of California dismisses cryptocurrency fraud lawsuit against banks, Stanford Federal Credit Union

Uncategorized
November 3, 2026

A California federal court dismissed a lawsuit alleging that several financial institutions helped carry out a $570,000 cryptocurrency scam, ruling that an anonymous married couple failed to state valid claims for aiding and abetting fraud and unauthorized wire...

Florida federal court denies motion to dismiss shareholder derivative lawsuit

Florida federal court denies motion to dismiss shareholder derivative lawsuit

Uncategorized
November 3, 2026

A Florida federal court refused to dismiss a lawsuit alleging that bank directors breached their fiduciary duties by changing corporate bylaws to protect their positions and prevent shareholders from removing them.

NEWSBYTES

FinCEN severs MEXC crypto exchange from U.S. financial system

November 6, 2026

Owen, Bowman discuss bank technology adoption, fighting fraud

November 6, 2026

Fed: Consumer credit increased 4.2% in Q3

November 6, 2026

SPONSORED CONTENT

Banking Technology at a Strategic Crossroads

Banking Technology at a Strategic Crossroads

October 29, 2026
The Shift from Demographic Marketing

The Shift from Demographic Marketing

October 1, 2026
Meeting Ag Lending Goals Without Going It Alone

Meeting Ag Lending Goals Without Going It Alone

October 1, 2026
Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

Beyond the Portfolio: The Wealth Manager’s New Role in a Multigenerational World

September 17, 2026

PODCASTS

Podcast: Proactively managing the core provider relationship

October 22, 2026

Podcast: How community banks can keep farmers farming in turbulent times

October 14, 2026

Podcast: The birth of American money and how it triggered a revolution

October 8, 2026

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2026 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2026 American Bankers Association. All rights reserved.