comment letter

CBA Submits Letter to House Small Business Committee ahead of Hearing entitled, “The End of Relationship Banking? Examining the CFPB’s ‘Small Business Lending Data Collection’ Rule”


Dear Chairman Meuser and Ranking Member Landsman:

The Consumer Bankers Association (CBA) is pleased to submit this letter for the hearing entitled “The End of Relationship Banking? Examining the CFPB’s “Small Business Lending Data Collection” Rule” focused on the Consumer Financial Protection Bureau’s (“CFPB” or “Bureau”) notice of proposed rulemaking for Small Business Lending Data Collection under the Equal Credit Opportunity Act (“proposal”), concerning the small business lending market pursuant to Section 1071 of the Dodd-Frank Act. CBA is the voice of the retail banking industry whose products and services provide access to credit to millions of consumers and small businesses. Our members operate in all 50 states, serve more than 150 million Americans, and collectively hold two-thirds of the country’s total depository assets.

CBA and its member institutions understand that Section 1071 was mandated by Congress; however, this rule is not as simple as data collection efforts undertaken on other lending products such as residential mortgages. Business loans are often complex and involve multiple owners who can be businesses themselves, not individual consumers which is an easier data point to capture. Business lending materially differs from residential mortgage lending and the use of Home Mortgage Disclosure Act (“HMDA”)-like reporting for business lending activity may not identify potential discrimination as Congress intended because of these important distinctions.

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