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Legal Update

Data Collection for Small Business Lending: How Much Is Enough?

23 May 2017
Mayer Brown Legal Update
On May 10, 2017, the US Consumer Financial Protection Bureau (“CFPB” or “Bureau”) took its first major step toward fulfilling its statutory obligation to implement the small business lending data collection requirement of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), a rulemaking that will serve as the foundation for fair lending examinations and enforcement in the small business lending space. Following a hearing during which Director Richard Cordray emphasized the importance of small businesses to the US economy, the Bureau issued a Request for Information (“RFI”) designed to enhance its understanding of how small business lending works. The RFI presents an opportunity for interested stakeholders to contribute to the Bureau’s knowledge of the market and potentially influence the development of the data collection rule. This Legal Update discusses the RFI, the Dodd-Frank Act’s data collection requirements and the ramifications for small business lenders.

Authors

  • Melanie Brody
    T +1 202 263 3304
  • Jeffrey P. Taft
    T +1 202 263 3293
  • Tori K. Shinohara
    T +1 202 263 3318
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