Recent Developments in the CFPB’s Small Business Data Collection Rule

Since the CFPB’s small business data collection rule became effective earlier this year, small business lenders have been making plans to implement the new and extensive data collection requirements. At the same time, the final rule has been the subject of litigation, with several financial institutions and trade associations suing the CFPB to enjoin the rule’s implementation. On July 31, a Texas court granted a preliminary injunction preventing the CFPB from implementing or enforcing the rule against the plaintiffs and their members. Please join Mayer Brown partners Tori Shinohara and Frank Doorley, with special guest Kate Rock of Guidehouse, for an update on the pending litigation, and a discussion of compliance considerations for lenders in the process of developing policies, procedures and processes to comply with the final rule.