Association Survey on CFPB Small Business Lending Data Collection Proposal

Deadline: December 31, 2021

In the Association’s continuing efforts to represent the interests of member credit unions before the Consumer Financial Protection Bureau (“Bureau”), your input on a pending proposal is requested using its online survey 08-21 relative to Small Business Lending Data Collection under the Equal Access to Credit Opportunity Act (Regulation B).

The Bureau has published for public comment a proposed rule amending Regulation B to implement changes to the Equal Credit Opportunity Act (“ECOA”) pursuant to section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”). Consistent with section 1071, the Bureau is proposing to require covered financial institutions to collect and report to the Bureau data on applications for credit for small businesses, including those that are owned by women and/or minorities. The Bureau’s proposal also addresses its approach to privacy interests and the publication of section 1071 data; shielding certain demographic data from underwriters and other persons; recordkeeping requirements; enforcement provisions; and the proposed rule’s effective and compliance dates.

The Bureau’s proposed voluminous rewrite of Regulation B’s provisions related to small business lending is lengthy at 251 pages as printed in the Federal Register. In consideration of the complexity and length of the proposal, the Association’s survey has been abbreviated for the convenience of respondents. For more information, a detailed summary is available HERE. Additional summary documents have been provided by the Bureau to assist the public in understanding this proposal, including an official summary of the proposal, a table of proposed data points for small business lending data collection, the table of contents of the proposal, and a summary of the Bureau’s estimation methodology.

The Bureau’s full proposal may be found HERE.

Access the Survey:

Members are encouraged to share the survey for completion with staff most appropriate to respond. The on-line survey prepared by the Association may be found at:


Please complete the survey at your earliest convenience. At this time, the survey will remain open through December 31, 2021.