Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the Equal Credit Opportunity Act (ECOA) to require financial institutions to compile, maintain, and submit to the Bureau certain data on credit applications by womenowned, minority-owned, and small businesses. These data include the census tract of the business and the race, sex, and ethnicity of the principal business owners, in addition to a number of other data points.1 Congress enacted Section 1071 for the purpose of facilitating enforcement of fair lending laws and enabling communities, governmental entities, and creditors to identify business and community development needs and opportunities for womenowned, minority-owned, and small businesses. The Bureau has interpreted Section 1071 to mean that obligations for financial institutions to collect and submit data “do not arise until the Bureau issues implementing regulations and those regulations take effect.”2