Over 10 years after announcing it would “expeditiously” implement provisions of the Dodd-Frank Act concerning data collection on small business lending, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) is finally taking action. On September 1, 2021, the CFPB issued a notice of proposed rulemaking on small business data collection. In this Legal Update, we summarize the CFPB’s proposed rulemaking and describe the consequences for small business lenders and other finance providers. We do not rehash each of the more than 900 pages of the Bureau’s proposal but instead summarize some of the most significant developments that small business lenders and finance providers should review when considering whether to provide comments to the Bureau regarding the proposed rule.
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