Newsroom
CFPB issues small biz data collection proposal
The CFPB Wednesday issued a proposal to amend Regulation B under Section 1071 of the Dodd-Frank Act requiring "covered financial institutions" to collect and report credit application data for small, women-owned, and minority-owned businesses. In addition, the proposal addresses the bureau's broader approach to privacy interests, including the shielding of certain applicant demographic data from underwriters.
“Credit unions support fair and affordable access to credit in the small business lending market,” said NAFCU President and CEO Dan Berger in response to the proposal. “The proposed rulemaking, however, raises concerns about how significant new data collection requirements will impact borrowers and smaller financial institutions like credit unions. As the Bureau continues to move this proposed rulemaking through the process, NAFCU will work to ensure that the complexities of section 1071 data collection are minimized in order to ensure credit availability and lender participation in the small business lending marketplace.”
Berger discussed the proposal with CFPB Acting Director Dave Uejio yesterday.
The proposal clarifies that a “covered financial institution” is a financial institution that satisfies an origination threshold of at least 25 credit transactions classified as covered credit transactions – including loans, lines of credit, credit cards, and merchant cash advances – to small businesses in each of the two preceding calendar years.
Of note, the CFPB is seeking comment on the costs to small financial institutions of collecting and reporting Section 1071 data regarding applications for credit for women-owned and minority-owned businesses that are not classified as small businesses; the bureau's definition of a "small business" – included in the proposal – takes into account whether the business had $5 million of less in gross annual revenue for its preceding fiscal year.
Comments on the proposal will be due 90 days after its publication in the Federal Register; compliance with the finalized rule would not be required until approximately 18 months after publication.
NAFCU previously called on the CFPB to exclude credit unions from any rulemaking requiring financial institutions to collect and report data related to small business lending, noting the member business lending constraints credit unions face and the increased costs associated with implementation of the data collection. The bureau last year released its Small Business Regulatory Enforcement Fairness Act (SBREFA) outline of proposals related to Section 1071 of the Dodd-Frank Act, which served a starting point for "engaging small entity representatives through the consultative process required under the SBREFA."
The association will review the proposal and continue to work with the CFPB on this topic. For more information, tomorrow’s post on the NAFCU Compliance Blog will cover the proposal.
Share This
Related Resources
Add to Calendar 2024-04-25 14:00:00 2024-04-25 14:00:00 ChatGPT: What AI can do for you! ChatGPT has been created with one main objective – to predict the next word in a sentence, based on what's typically happened in the gigabytes of text data that it's been trained on. Did you ever hear of the saying, “People fear the unknown?” Artificial intelligence scares people, but it is the future, and you need to understand the tools and resources it offers. It’s also about saving time, that’s what technology and in this case, artificial intelligence can do for you. If you want to save time and have a better quality of life, this training is for you. Once you give ChatGPT a question or prompt, it passes through the AI model and the chatbot produces a response based on the information you've given and how that fits into its vast amount of training data. It's during this training that ChatGPT has learned what word, or sequence of words, typically follows the last one in a given context. During this webinar, ChatGPT: What AI can do for you, you’ll discover the background, purpose, usability, and the pros and cons. Don't miss this opportunity! Key Takeaways Learn the background of AI Understand the purpose of AI Identify the pros and cons Register Now $295 Members | $395 Nonmembers(Additional $50 for USB)One registration gives your entire team access to the live webinar and on-demand recording until April 25, 2025Go to the Online Training Center to access the webinar after purchase » Who Should Attend NCRMs Risk titles Education Credits NCRMs will recieve 1.0 CEUs for participating in this webinar Web NAFCU digital@nafcu.org America/New_York public
ChatGPT: What AI can do for you!
Credits: NCRM
Webinar
Add to Calendar 2024-04-25 14:00:00 2024-04-25 14:00:00 Unifying Two Different Executive Benefits Programs About the Webinar In part one we discussed how to retain key positions during a time of transition. In part two, we will look at how to combine executive benefits programs from two different organizations into a single high-performing program. Evaluating each program includes many different facets, from strategy and expense to performance and servicing. This session will provide important considerations, whether or not you have pending M&A activity. Key Takeaways: Is the plan design both retentive and efficient? Is the benefit expense properly mitigated? Does the legal agreement reflect the board’s intent? View On-Demand Web NAFCU digital@nafcu.org America/New_York public
Unifying Two Different Executive Benefits Programs
preferred partner
Gallagher
Webinar
Add to Calendar 2024-04-24 14:00:00 2024-04-24 14:00:00 Optimize Liquidity, Maximize Loan Growth: The Network Lending Advantage About The Webinar Join us to learn more about network lending, a cooperative model allowing credit unions to optimize liquidity and achieve loan growth. Discover how credit unions can participate in loan pools with other institutions, allowing them to diversify portfolios, access loans with potentially lower risk and higher yields, and expand lending capacity without necessarily needing a surge in deposits. Delve into how credit unions can pool their resources, set common underwriting and pricing standards, and collectively originate, buy, and sell loans to optimize liquidity management. Hear from your peers about best practices, case studies, and practical strategies to harness the full potential of network lending and how it's helped their credit unions. Don't miss this valuable opportunity to learn how to strengthen your credit union's position in today’s competitive environment. Key Takeaways: How network lending differs from traditional lending The benefits of participating in loan pools with other credit unions How credit unions can set common underwriting and pricing standards and collectively originate, buy and sell loans to optimize liquidity management Why network lending is critical to loan growth Watch On-Demand Web NAFCU digital@nafcu.org America/New_York public
Optimize Liquidity, Maximize Loan Growth: The Network Lending Advantage
preferred partner
LendKey
Webinar
Add to Calendar 2024-04-23 14:00:00 2024-04-23 14:00:00 Monitoring the Latest Litigation Risks Credit unions’ operations pose litigation risks, with more of these cases being filed as class action lawsuits. In this Monitoring the Latest Litigation Risks for Credit Unions webinar, you’ll review some of the specific kinds of lawsuits impacting credit unions and what potential claims could be on the horizon. You’ll also examine some options for mitigating risks. Key Takeaways Review the current lawsuit trends. Understand the potential claims risks Explore options for mitigating risks. Register Now $295 Members | $395 Nonmembers(Additional $50 for USB)One registration gives your entire team access to the live webinar and on-demand recording until April 23, 2025Go to the Online Training Center to access the webinar after purchase » Who Should Attend NCCOs NCRMs Compliance and risk titles Education Credits NCRMs will recieve 1.0 CEUs for participating in this webinar NCCOs will recieve 1.0 CEUs for participating in this webinar Web NAFCU digital@nafcu.org America/New_York public
Monitoring the Latest Litigation Risks
Credits: NCCO, NCRM
Webinar
Get daily updates.
Subscribe to NAFCU today.