Our comment letter in response to the Consumer Financial Protection Bureau’s (CFPB) proposed rule implementing section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act shares our concerns that this proposal goes too far restricting small business lending data collection, resulting in serious weaknesses and exclusions that run counter to the goals of disclosing this data to the public.
Woodstock’s research and policy advocacy relies heavily on mortgage data made available by the Home Mortgage Disclosure Act. This data allows the public to identify disparities in access to homeownership and advocate for greater lending in disinvested communities. Section 1071of Dodd-Frank would make available similar data for small business lending, a key pillar of community economic development.
The CFPB’s proposed rule implementing collection of this small business lending data would not be doing Section 1071 justice. We highlight three particular areas of concern: excluding merchant cash advances, excluding small farm lending, and raising the loan count threshold for reporting.
