Removing Barriers Blog

CUNA Submits Comments to CFPB on RFI for Small Business Lending Market

Yesterday, CUNA’s Senior Director of Advocacy and Counsel Leah Dempsey, submitted comments to the CFPB in response to their Request for Information (RFI) Regarding the Small Business Lending Market. 

In the letter, CUNA outlines concerns about the likely unintended consequences of having to collect additional data for small business loans, which because of their diverse and unique fields of membership would not align with practices for collecting data by the large Wall Street banks and other financial service providers.  

Credit unions’ not-for-profit, cooperative structure and regulatory requirements--which includes supervision by a prudential regulator that imposes specific business lending requirements--is substantially different than other participants in this market. Credit unions also, by their very mission, seek to provide safe and affordable products and services to consumers in need. While CUNA strongly supports the intent of Section 1071 and the Equal Credit Opportunity Act, there are serious concerns about unintended consequences that could result from a rule requiring additional data collection. 

Additionally, the collection of more data could do more harm than good by creating additional regulatory barriers for credit unions seeking to provide member business loans. Comparable data collection requirements as suggested by the CFPB in this RFI have proven to be extremely burdensome to credit unions and will likely impact credit union participation in the small business lending market. 

As with previous RFIs and Rules the CFPB has released or implemented, CUNA again urges the CFPB to use their authority under Section 1022 of the Dodd-Frank Act to exempt credit unions from any additional data collection requirements.  

CUNA appreciates the opportunity to inform the CFPB of the unintended consequences additional data collection may have on the credit union industry and looks forward to continued dialogue on the topic.