Comments to the Consumer Financial Protection Bureau (Request for Stakeholder Feedback)
Section 1071 of the Dodd Frank Act was designed to encourage the enforcement of fair lending laws and empower communities, government agencies, and lenders to identify underserved community development needs. The section amends the Equal Credit Opportunity Act to require additional small business data collection. We believe section 1071 will greatly improve the ability of researchers to identify systematic discrimination in small business credit markets. We believe there is a need for an expansive definition of covered credit products and that the Bureau should require financial institutions to report what it currently considers as “discretionary” data points. However, the Bureau must be careful to avoid unintended consequences by increasing the compliance costs of extremely small community-oriented lending institutions.
WHY THIS MATTERS
After the financial crisis of 2008, large banking institutions are less likely to extend credit to small businesses. Individuals from underserved communities – including minorities and women – are among the groups most likely to face structural challenges in accessing the capital they need to grow and expand their entrepreneurial ventures. Section 1071 will provide more data to highlight these issues because it expands reporting requirements related to small business lending activity.
VIEW CSBDF’S FULL PUBLIC COMMENT:
Carolina Small Business Development Fund. 2020. “Stakeholder Feedback to the Consumer Financial Protection Bureau: Outline of Proposals Under Consideration and Alternatives Considered for Section 1071 of the Dodd-Frank Act.” http://carolinasmallbusiness.org/publications/cfpb-section-1071/.