On March 30, 2023, the Consumer Financial Protection Bureau (CFPB) issued the small business lending rule (Final Rule) which implements the small business lending data collection requirements set for in Section 1071 of the Dodd-Frank Act (Section 1071). Section 1071 amended the Equal Credit Opportunity Act (ECOA) to require financial institutions to compile data regarding certain business credit applications and report that data to the CFPB.
Under the Final Rule, lenders who originate at least 100 covered originations in each of the two preceding calendar years would be required to collect and report information about the small business credit applications they received, including geographic and demographic data, lending decisions and the price of credit. These data points include: (i) a unique identifier, (ii) the application date; (iii) the application method; (iv) the application...
