CFPB Finalizes Long-Awaited Small Business Data Collection Rule
On March 30, 2023, the US Consumer Financial Protection Bureau (“CFPB”) published its long-awaited final rule requiring lenders to collect and report data about their small business lending activities. The final rule implements Section 1071 of the Dodd-Frank Act, which was designed to facilitate enforcement of fair lending laws with respect to women-owned, minority-owned and small businesses. The final rule was issued just one day before a court-mandated deadline for finalization, and more than 10 years after the enactment of the Dodd-Frank Act.
As those who reviewed the proposed version of the rule may suspect, the requirements under the 888-page finalized rule are extensive. For lenders already used to complying with reporting requirements for mortgage loans under the Home Mortgage Disclosure Act (“HMDA”), the implementation process will be challenging. But for lenders who do not currently collect and report under HMDA, implementation of the Section 1071 final rule is likely to be particularly taxing.
Please join Mayer Brown lawyers Tori Shinohara, Frank Doorley and Kerri Webb as they discuss the key aspects of the final rule and its potential implications for your business.
For additional information about this event, please contact Molly McGrail at mmcgrail@mayerbrown.com.