Comments Due to NAFCU: CFPB - Small Business Lending Data Collection under the Equal Credit Opportunity Act
NAFCU would like to highlight the following:
- The Proposed Rule would require credit unions and credit union service organizations (CUSOs) that originated at least 25 covered small business credit transactions in each of the two preceding calendar years to collect and report certain small business credit application data, including data related to the ethnicity, race, and sex of business applicants’ principal owners.
- The Bureau is seeking Small Business Administration (SBA) approval to define a “small business” for Regulation B purposes as any business that had $5 million or less in gross annual revenue in its preceding fiscal year.
- The Proposed Rule would generally require that credit unions and CUSOs establish a “firewall” to shield certain small business credit applicant data from underwriters and other persons involved in application determinations.
Comments due to NAFCU: December 6, 2021
Comments due to the CFPB: January 6, 2022
NAFCU will send comments on behalf of its members to the CFPB by their deadline (January 6, 2022).