How We Support Section 1071 Compliance
CrossCheck helps institutions address Section 1071 compliance as both a regulatory reporting obligation and a fair lending risk management issue.
Our work is designed to help lenders understand whether they are prepared to collect, maintain, and report small business lending data accurately, while also supporting the governance, documentation, and testing needed to withstand examiner and stakeholder scrutiny. We assess the practical realities of implementation, including product scoping, covered application determinations, data collection workflows, action taken coding, demographic information handling, and ongoing quality control.
- Data collection and workflow design
We review intake processes, application workflows, and data capture practices to help institutions operationalize demographic data collection, applicant responses, and required reporting fields in a consistent and compliant manner. - Firewall and access review
We assess whether demographic information is appropriately restricted within the lending process and evaluate operational controls designed to support the firewall requirements and related exception handling. - Data mapping and field validation
We review how required data fields are defined, sourced, mapped, and populated across systems to identify inconsistencies, logic issues, or operational gaps that could affect reporting accuracy. - Action taken and denial reason testing
We evaluate how action taken codes, dates, and denial reasons are assigned to help institutions reduce misreporting risk and improve consistency across products and business lines. - Data integrity and scrub support
We test sample data and reporting logic to identify errors, missing fields, formatting issues, and anomalies before submission, helping institutions strengthen the reliability of their Section 1071 dataset. - Governance and documentation review
We assess policies, procedures, training, role allocation, and compliance documentation to support implementation, examination readiness, and internal accountability.
Meet your Section 1071 Compliance Experts
Section 1071 Compliance FAQs
What is Section 1071 Compliance?
Section 1071 compliance refers to the policies, processes, systems, and controls a lender uses to meet federal small business lending data collection and reporting requirements. It typically includes determining coverage, collecting required applicant and application data, maintaining appropriate controls around demographic information, and preparing accurate annual reporting.
Why is Section 1071 important for lenders?
Section 1071 creates both a regulatory reporting obligation and a fair lending risk management expectation. Lenders need to collect and report small business lending data accurately, but they also need to ensure that implementation decisions, data quality practices, and related controls can stand up to regulatory review and support broader compliance oversight.
What does CrossCheck review as part of a Section 1071 compliance engagement?
Can you help determine whether Section 1071 applies to our institution or products?
Do Section 1071 services include data integrity testing and scrubs?
What are firewall requirements in the Section 1071 context?
Firewall requirements generally relate to restricting certain employees involved in credit decisions from accessing an applicant’s demographic information, subject to applicable exceptions and disclosure requirements. Reviewing workflow design and access controls helps institutions integrate those requirements more effectively.
Can CrossCheck help if we are still building our Section 1071 program?
What do institutions gain from a Section 1071 compliance review?
Is Section 1071 compliance a one-time project or an ongoing process?
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