In response to the CFPB’s outline of proposals to implement section 1071 of the Dodd-Frank Act requiring financial institutions to collect and report data related to small business lending, NAFCU reiterated its call to exclude credit unions from the rulemaking noting the member business lending constraints credit unions face and the increased costs to implement the data collection.
The outline of proposals, required by the Small Business Regulatory Enforcement Fairness Act (SBREFA), was released in September and explains the scope of proposed rule, various definitions for financial institutions and applications, products covered, potential data points, data privacy considerations, the rulemaking’s potential impact on small entities, and the impact on cost and availability of credit to small entities.
While NAFCU has consistently urged the bureau to exempt credit unions from a rulemaking on this issue as it will add significant regulatory burdens on small institutions, the outline of proposals did not include this explicit exemption. However, other combinations of exemptions are under consideration, including whether to combine size- and activity-based approaches to possible collection and reporting exemptions for financial institutions.
NAFCU Senior Counsel for Research and Policy Andrew Morris, in the letter sent to the bureau Monday, highlighted credit unions’ support for promoting access to small business credit on fair and equitable terms.
continue reading »