Earlier this week, the American Financial Services Association (AFSA) submitted comments on the Consumer Financial Protection Bureau's (CFPB) proposal to amend small business lending data collection requirements under Section 1071 of the Dodd-Frank Act. The proposal aims to streamline data collections and establish a simplified compliance date structure for all affected lenders, with a proposed compliance date of January 1, 2028.
AFSA has been involved in this issue since before the first proposal was issued in 2021. The association has consistently advocated for simplifying data collection and reporting obligations. AFSA has also requested exclusions from coverage by the 1071 Rule for indirect vehicle finance transactions, floorplan financing, merchant-initiated credit applications, and other forms of credit offered by its members.
The CFPB is currently facing operational challenges due to a lack of funding, which may affect how quickly it can finalize its review of comments and prepare final rulemaking on this subject. "We understand the CFPB may choose to issue an interim final rule on an expedited basis in order to wrap this up before becoming insolvent," AFSA noted. The organization will continue to monitor developments closely.
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