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  • CFPB announces meetings for small business lending data reporting

    Federal Issues

    On August 8, the CFPB announced that it is hosting two events to discuss the technical implementation required to prepare for the Bureau’s Small Business Lending Data Collection Rulemaking, which is a requirement under Section 1071 of the Dodd-Frank Act. According to the Bureau, the meetings will be geared toward in-house bank technologists or providers that provide compliance software to banks. Among other things, the meetings will: (i) share how the Bureau builds regulatory compliance technology systems; (ii) discuss possible approaches to authentication and application programming interfaces; and (iii) review technical data submission standards, edits and validations. The Bureau stated that the meetings “will not discuss or seek input on the merits or potential outcome of any ongoing rulemakings or take questions pertaining to the substance of such rulemakings.” According to the CFPB’s spring rulemaking agenda that was released earlier this summer, a final rule is expected in March 2023 (covered by InfoBytes here).

    Federal Issues CFPB Dodd-Frank Small Business Lending Debt Collection Section 1071

  • District Court orders CFPB to issue Section 1071 rulemaking by March 31

    Federal Issues

    On July 11, the U.S. District Court for the Northern District of California issued an order setting March 31, 2023 as the deadline for the CFPB to issue a notice of proposed rulemaking (NPRM) on small business lending data. As previously covered by InfoBytes, the Bureau is obligated to issue an NPRM for implementing Section 1071 of the Dodd-Frank Act, which requires the agency to collect and disclose data on lending to women and minority-owned small businesses. The requirement was established as part of a stipulated settlement reached in 2020 with a group of plaintiffs, including the California Reinvestment Coalition (CRC), who argued that the Bureau’s failure to implement Section 1071 violated two provisions of the Administrative Procedures Act, and harmed the CRC’s ability to advocate for access to credit, advise organizations working with women and minority-owned small businesses, and work with lenders to arrange investment in low-income and communities of color (covered by InfoBytes here).

    Find continuing Section 1071 coverage here.

    Federal Issues Courts Agency Rule-Making & Guidance CFPB Small Business Lending Section 1071 Consumer Finance Dodd-Frank

  • CFPB publishes rulemaking agenda

    Federal Issues

    Recently, the Office of Information and Regulatory Affairs released the CFPB’s spring 2022 rulemaking agenda. According to the preamble, the information in the agenda is current as of April 1, 2022 and identifies regulatory matters that the Bureau “reasonably anticipates having under consideration during the period from June 1, 2022 to May 31, 2023.”

    Key rulemaking initiatives include:

    • Consumer Access to Financial Records. The Bureau notes that it is considering rulemaking to implement section 1033 of the Dodd-Frank Act to address the development and use of standardized formats for information made available to consumers. The Bureau will release materials in advance of convening a panel under the Small Business Regulatory Enforcement Fairness Act (SBREFA), in conjunction with the Office of Management and Budget and the Small Business Administration’s Chief Counsel for Advocacy.
    • Amendments to FIRREA Concerning Automated Valuation Models. The Bureau is participating in interagency rulemaking with the Fed, OCC, FDIC, NCUA, and FHFA to develop regulations to implement the amendments made by the Dodd-Frank Act to FIRREA concerning appraisal automated valuation models (AVMs). The FIRREA amendments require implementing regulations for quality control standards for AVMs. The Bureau released a SBREFA outline in February 2022 and estimates in the agenda that the agencies will issue an NPRM in December 2022 (covered by InfoBytes here).
    • Property Assessed Clean Energy Financing. The Bureau issued an ANPR in March 2019 to extend TILA’s ability-to-repay requirements to PACE transactions (covered by InfoBytes here). The Bureau is working to develop a proposed rule to implement Economic Growth, Regulatory Relief, and Consumer Protection Act section 307 in May 2023.
    • Small Business Lending Data Collection Under the Equal Credit Opportunity Act. Section 1071 of the Dodd-Frank Act amended ECOA to require financial institutions to report information concerning credit applications made by women-owned, minority-owned, and small businesses, and directed the Bureau to promulgate rules for this reporting. The Bureau issued an NPRM in August 2021, and the comment period ended January 6 (covered by InfoBytes here). The agenda indicates that the Bureau estimates issuance of a final rule in March 2023.
    • Adverse Information in Cases of Human Trafficking Under the Debt Bondage Repair Act. The National Defense Authorization Act amended the FCRA to prohibit consumer reporting agencies from providing reports containing any adverse items of information resulting from human trafficking. In June 2022, the CFPB issued a final rule implementing amendments to the FCRA intended to assist victims of human trafficking (covered by InfoBytes here).

    Federal Issues Agency Rule-Making & Guidance CFPB Dodd-Frank Small Business Lending SBREFA PACE Programs AVMs Bank Regulatory Section 1033 Section 1071 ECOA FCRA OCC Federal Reserve FDIC NCUA FHFA

  • CFPB reviewing 2,100 comments on small business data collection

    Federal Issues

    On February 22, the CFPB filed its eighth status report in the U.S. District Court for the Northern District of California, as required under a stipulated settlement reached in February 2020 with a group of plaintiffs, including the California Reinvestment Coalition, related to the collection of small business lending data. The settlement (covered by InfoBytes here) resolved a 2019 lawsuit that sought an order compelling the Bureau to issue a final rule implementing Section 1071 of the Dodd-Frank Act, which requires the Bureau to collect and disclose data on lending to women and minority-owned small businesses. The current status report states that the Bureau has met the deadlines under the stipulated settlement, which included issuing its long-awaited proposed rule (NPRM) last September. As covered by a Buckley Special Alert, the NPRM would require a broad swath of lenders to collect small business loan data, including information about the loans themselves, borrower characteristics, and demographic information regarding the borrower’s principal owners. This information would be reported annually to the Bureau and published by the Bureau on its website. The Bureau notes in its status report that the NPRM’s comment period ended on January 6. The Bureau is currently reviewing approximately 2,100 comments submitted via the public docket and will confer with plaintiffs regarding an appropriate deadline for issuing a final rule.

    Find continuing Section 1071 coverage here.

    Federal Issues CFPB Section 1071 Small Business Lending Dodd-Frank Courts SBREFA Agency Rule-Making & Guidance

  • CBA urges CFPB to supervise nonbank small business lenders

    Federal Issues

    On February 9, the Consumer Bankers Association (CBA) sent CFPB Director Rohit Chopra a letter regarding the supervision of nonbank small business lenders. The letter noted that the landscape for business lending has recently altered “substantially,” specifically with the alternative banking options offered by financial technology companies having “significant market share.” The letter considered small businesses to be “vulnerable” because the activities of fintechs engaged in small business lending are not supervised by the Bureau. The letter urged the Bureau to “evaluate all possible avenues for supervising these nonbank small business lenders, including adding nonbank small business lending to the larger participant rule.” The letter also pointed out that the “lack of supervisory authority over nonbank small business lenders” undermines the CFPB’s other regulatory efforts, such as identifying and addressing fair lending concerns through a final rule covering small business lending data collection pursuant to Section 1071 of Dodd-Frank. The CBA argued that the absence of authority over nonbank lenders “will negatively impact the accuracy and utility of any data the Bureau receives under a Section 1071 final rule.” The CBA also advised the Bureau to utilize its ability under 12 U.S.C. Section 5514 to increase its authority over larger participants in the small business lending market.

    Federal Issues CFPB Nonbank Small Business Lending Nonbank Lending Fair Lending Dodd-Frank Section 1071

  • NYDFS concerned with CFPB’s small business loan data collection proposal

    Agency Rule-Making & Guidance

    On January 6, NYDFS issued a comment letter responding to the CFPB’s Notice of Proposed Rulemaking (NPRM), “Small Business Lending Data Collection under the Equal Credit Opportunity Act (Regulation B).” The NPRM—mandated under Section 1071 of the Dodd-Frank Act—would require a broad swath of lenders to collect data on loans they make to small businesses, including information about the loans themselves, the characteristics of the borrower, and demographic information regarding the borrower’s principal owners. This information would be reported annually to the Bureau, and eventually published by the Bureau on its website, with some potential modifications. According to the Bureau, the statute’s stated intent is to “facilitate enforcement of fair lending laws and enable communities, governmental entities, and creditors to identify business and community development needs and opportunities of women-owned, minority-owned, and small businesses.” (Covered by a Buckley Special Alert.)

    In its comment letter, NYDFS discussed its responsibilities for examining state-chartered banking institutions’ compliance with the New York Community Reinvestment Act (NYCRA), New York Banking Law § 28-b, which NYDFS noted largely mirrors the current federal Community Reinvestment Act (CRA). Additionally, NYDFS stated that it examines regulated institutions for compliance with state fair lending requirements and agreed with the Bureau that “collecting critical information about minority- and women-owned businesses (MWOBs) to address fair lending concerns and allow financial institutions to identify gaps in the market” is an important goal. To that end, NYDFS is in the process of implementing its own MWOB data collection regulation under the NYCRA, which would require New York state-chartered banking institutions to start collecting MWOB-related data. (Covered by InfoBytes here.) Due to similarities between the proposed regulation and the Bureau’s NPRM, and to avoid imposing an undue burden on institutions covered by both regulations, NYDFS’s proposed regulation includes language that would “permit, but not obligate, NYDFS to treat compliance with the CFPB’s rule implementing Section 1071 as compliance with the NYCRA’s MWOB-related data collection regulation.”

    Two specific issues were raised in response to the Bureau’s NPRM. First, NYDFS expressed concerns about the NPRM’s silence as to whether the Bureau intends to share more detailed data with state regulators to help states identify fair lending violations and enforce anti-discrimination laws, even if this information is not made available to the public. NYDFS urged the Bureau to include specific language stating it “may share all data submitted by financial institutions with state regulators in accordance with information sharing agreements between the CFPB and the state regulators.” Second, NYDFS asked the Bureau to reconsider its proposal to require data collection only for MWOBs with a threshold of $5 million or less in gross annual revenue. In particular, NYDFS warned of the risk of “dissimilarity in data collected by lenders for submission to the CFPB and the NYDFS” as NYDFS’s proposed regulation “requires evaluation of MWOB lending without respect to size.” NYDFS stressed that this dissimilarity “may prevent the NYDFS from deeming compliance with the CFPB regulation sufficient to comply with the NYDFS regulation.”

    Agency Rule-Making & Guidance CFPB Section 1071 Small Business Lending NYDFS ECOA State Issues State Regulators New York

  • CFPB publishes fall 2021 rulemaking agenda

    Agency Rule-Making & Guidance

    On December 13, the Office of Information And Regulatory Affairs released the CFPB’s fall 2021 rulemaking agenda. According to a Bureau announcement, the information released represents regulatory matters the Bureau plans to pursue during the period from November 2, 2021 to October 31, 2022. Additionally, the Bureau stated that the latest agenda reflects continued rulemakings intended to further its consumer financial protection mission and help advance the country’s economic recovery from the Covid-19 pandemic. Promoting racial and economic equity and supporting underserved and marginalized communities’ access to fair and affordable credit continue to be Bureau priorities.

    Key rulemaking initiatives include:

    • Small Business Rulemaking. This fall, the Bureau issued its long-awaited proposed rule (NPRM) for Section 1071 regulations, which would require a broad swath of lenders to collect data on loans they make to small businesses, including information about the loans themselves, the characteristics of the borrower, and demographic information regarding the borrower’s principal owners. (Covered by a Buckley Special Alert.) The NPRM comment period goes through January 6, 2022, after which point the Bureau will review comments as it moves to develop a final rule. Find continuing Section 1071 coverage here.
    • Consumer Access to Financial Records. The Bureau noted that it is working on rulemaking to implement Section 1033 of Dodd-Frank in order to address the availability of electronic consumer financial account data. The Bureau is currently reviewing comments received in response to an Advance Notice of Proposed Rulemaking (ANPR) issued fall 2020 regarding consumer data access (covered by InfoBytes here). Additionally, the Bureau stated it is monitoring the market to consider potential next steps, “including whether a Small Business Review Panel is required pursuant to the Regulatory Flexibility Act.”
    • Property Assessed Clean Energy (PACE) Financing. As previously covered by InfoBytes, the Bureau published an ANPR in March 2019 seeking feedback on the unique features of PACE financing and the general implications of regulating PACE financing under TILA (as required by Section 307 of the Economic Growth, Regulatory Relief, and Consumer Protection Act, which amended TILA to mandate that the Bureau issue certain regulations relating to PACE financing). The Bureau noted that it continues “to engage with stakeholders and collect information for the rulemaking, including by pursuing quantitative data on the effect of PACE on consumers’ financial outcomes.”
    • Automated Valuation Models (AVM). Interagency rulemaking is currently being pursued by the Bureau, Federal Reserve Board, OCC, FDIC, NCUA, and FHFA to develop regulations for AVM quality control standards as required by Dodd-Frank amendments to FIRREA. The standards are designed to, among other things, “ensure a high level of confidence in the estimates produced by the valuation models, protect against the manipulation of data, seek to avoid conflicts of interest, require random sample testing and reviews,” and account for any other appropriate factors. An NPRM is anticipated for June 2022.
    • Amendments to Regulation Z to Facilitate LIBOR Transition. As previously covered by InfoBytes, the Bureau issued a final rule on December 7 to facilitate the transition from LIBOR for consumer financial products, including “adjustable-rate mortgages, credit cards, student loans, reverse mortgages, [and] home equity lines of credit,” among others. The final rule amended Regulation Z, which implements TILA, to generally address LIBOR’s eventual cessation for most U.S. dollar settings in June 2023, and establish requirements for how creditors must select replacement indices for existing LIBOR-linked consumer loans. The final rule generally takes effect April 1, 2022.
    • Reviewing Existing Regulations. The Bureau noted in its announcement that it decided to conduct an assessment of a rule implementing HMDA (most of which took effect January 2018), and referred to a notice and request for comments issued last month (covered by InfoBytes here), which solicited public comments on its plans to assess the effectiveness of the HMDA Rule. Additionally, the Bureau stated that it finished a review of Regulation Z rules implementing the Credit Card Accountability Responsibility and Disclosure Act of 2009, and that “[a]fter considering the statutory review factors and public comments,” it “determined that the CARD Act rules should continue without change.”

    Notably, there are 14 rulemaking activities that are listed as inactive on the fall 2021 agenda, including rulemakings on overdraft services, consumer reporting, student loan servicing, Regulation E modernization, abusive acts and practices, loan originator compensation, and TILA/RESPA mortgage disclosure integration.

    Agency Rule-Making & Guidance CFPB Covid-19 Small Business Lending Section 1071 Consumer Finance PACE Programs AVMs Dodd-Frank Section 1033 Regulation Z LIBOR HMDA RESPA TILA CARES Act Debt Collection EGRRCPA Federal Reserve OCC FDIC NCUA FHFA Bank Regulatory FIRREA CARD Act

  • CFPB updates status on data collection rulemaking

    Federal Issues

    On November 22, the CFPB filed its seventh status report in the U.S. District Court for the Northern District of California as required under a stipulated settlement reached in February 2020 with a group of plaintiffs, including the California Reinvestment Coalition, related to the collection of small business lending data. The settlement (covered by InfoBytes here) resolved a 2019 lawsuit that sought an order compelling the Bureau to issue a final rule implementing Section 1071 of the Dodd-Frank Act, which requires the Bureau to collect and disclose data on lending to women and minority-owned small businesses. The newest status report states that the Bureau has met its deadlines under the stipulated settlement, which included issuing its long-awaited proposed rule (NPRM) in September. As covered by a Buckley Special Alert, the NPRM would require a broad swath of lenders to collect data on loans they make to small businesses, including information about the loans themselves, the characteristics of the borrower, and demographic information regarding the borrower’s principal owners. This information would be reported annually to the Bureau and published by the Bureau on its website. Comments on the NPRM are due January 6, 2022. Among other things, the Bureau notes in its status report that once the Section 1071 NPRM comment period concludes, it will meet and confer with plaintiffs to discuss an “appropriate deadline” for issuing the final rule, consistent with the stipulated settlement.

    Find continuing Section 1071 coverage here.

    Federal Issues CFPB Section 1071 Small Business Lending Dodd-Frank

  • CFPB deputy director discusses future rulemaking research efforts

    Federal Issues

    On November 5, CFPB Deputy Director Zixta Martinez spoke before the Bureau’s Academic Research Council (ARC) meeting, in which she discussed recent research efforts taken to inform future rulemaking and identify root causes of challenges facing consumers. Martinez highlighted Section 1022 orders recently sent to several big tech payment platforms seeking information on their products, plans, and practices (covered by InfoBytes here). She noted that the evaluation of these companies’ payments platform data will help inform the Bureau on the future of the payments system as well as potential emerging risks, and will provide insights that may impact future rulemaking under Section 1033 concerning the disclosure of consumer data by regulated entities. Among other things, Martinez also discussed the importance of small business lending research to better understand whether these businesses provide fair and equitable access to credit and referred to the Bureau’s Section 1071 notice of proposed rulemaking issued in September (covered by a Buckley Special Alert). Martinez also noted that one of the Bureau’s priorities is ensuring access to fair and affordable credit for low-income, minority, or traditionally underserved communities, and said the Office of Research will solicit “suggestions and advice for ways to integrate racial and economic equity analyses into the CFPB’s research agenda.”

    Federal Issues CFPB Agency Rule-Making & Guidance Section 1033 Payments Section 1071 Small Business Lending Fair Lending

  • Special Alert: CFPB proposes small business loan data collection regime

    Federal Issues

    Over a decade ago, Congress enacted an amendment to the Equal Credit Opportunity Act that directed the Consumer Financial Protection Bureau to implement a new regime for small business loan data collection similar to the regime that exists in the mortgage industry. Last week, a month before a court-imposed deadline, the Bureau issued its long-awaited proposed rule. The proposal was largely consistent with prior Bureau statements regarding its approach, but nonetheless contained some surprises that reflect the change in leadership at the CFPB. Lenders will need to carefully assess the impact of the proposed rule on their business.

    The proposed rule, which is mandated under Section 1071 of the Dodd-Frank Act, would require a broad swath of lenders to collect data on loans they make to small businesses, including information about the loans themselves, the characteristics of the borrower, and demographic information regarding the borrower’s principal owners. This information would be reported annually to the Bureau, and eventually published by the Bureau on its website, with some potential modifications.

    The statute’s stated intent is to “facilitate enforcement of fair lending laws and enable communities, governmental entities, and creditors to identify business and community development needs and opportunities of women-owned, minority-owned, and small businesses.” CFPB Acting Director Dave Uejio echoed these themes in prepared remarks, suggesting that the proposal was a step towards “a fairer, more transparent small business lending market.” But the Bureau itself acknowledges that it is engaged in a balancing exercise, weighing the intended benefits of the rule against the cost imposed on lenders (and by extension, borrowers), the risk to privacy interests, and the risk of unintended consequences that accompany any major regulatory intervention. The public, including lenders potentially subject to the rule, have 90 days to submit comments on whether the Bureau got the balance right.

    The proposed rule would cover most of the small business lending market

    By its terms, the statute would apply broadly to any “financial institution” that extended credit to any women-owned, minority-owned, or small business. But the statute also allowed the Bureau to exempt any “class of financial institutions” from its requirements. Last fall, as part of a process required under the Small Business Regulatory Enforcement Fairness Act (SBREFA), the Bureau suggested that it might exempt lenders based on their size (i.e., those beneath thresholds of $100 million or $200 million in assets), their loan activity (i.e., those making 25, 50, or 100 or fewer loans annually), or based on either threshold. The proposed rule lands at the broadest end of this possible spectrum, abandoning any exemptions based on size altogether and adopting the lowest of the proposed activity levels. Any financial institution that originates at least 25 “covered credit transactions” for “small businesses” in each of the two preceding years would be subject to the rule.

    Any loan, line of credit, credit card, or merchant cash advance, including agricultural-purpose credit and those that are also covered by HMDA, would be considered a “covered credit transaction.”[1] Notably, the Bureau suggested in its SBREFA Outline that it would exclude merchant cash advances, but declined to do so in the proposal, concluding that the segment is growing and presents unique fair lending risk.

    Just as it did in its SBREFA Outline, the Bureau would adopt the Small Business Administration’s definition of “small business,” except that the Bureau’s definition would use a simplified size threshold of $5 million or less in gross annual revenue. This divergence will require SBA approval, which Uejio expressed confidence in getting.

    The proposal’s collection requirements are triggered whenever a lender subject to the rule under the activity threshold receives a “covered credit application.” This term is defined broadly to include “any oral or written request for a covered credit transaction that is made in accordance with procedures used by [the] financial institution for the type of credit requested.” Reevaluation requests, extension requests, and renewal requests would not be considered applications (unless the request seeks additional credit amounts), nor would inquiries and prequalification requests.

    The rule would require the collection of 21 data points

    The statute sets forth thirteen specific data points to be collected by lenders that the Bureau refers to as “mandatory data points:”

    • Whether the applicant is minority-owned
    • Whether the applicant is women-owned
    • Unique identifier for each application
    • Application date
    • Loan type (i.e., product type, guarantees, and term)
    • Loan purpose
    • Amount applied for
    • Amount approved or extended
    • The action on the application (i.e., originated, approved but not accepted, denied, withdrawn, or incomplete)
    • Action date
    • Census tract
    • Gross annual revenue
    • Race, sex, and ethnicity of the principal owners

    The collection of information about the principal owner’s[2] race, sex, and ethnicity is a major change from the SBREFA Outline, which suggested that the Bureau would likely propose the collection of such information solely based on applicant self-reporting. As the Bureau recognized at the time, “requiring reporting based on visual observation or surname could create unwarranted compliance burdens in the context of small business lending.” The proposal reverses course, and would require lenders who meet with any principal owner to determine the ethnicity and race of the principal owner if the applicant declines to provide that information. As the statute requires, the data collected regarding the principal owners’ race, sex, and ethnicity—as well as whether the business is minority-owned or women-owned—must not be shared with underwriters, unless restricting access is not feasible.[3]

    The statute also authorized the Bureau to require additional data that would advance the purposes of the statute (so-called “discretionary data points”). The CFPB’s proposed discretionary data points are consistent with this administration’s prioritization of fair lending enforcement:

    • Pricing
    • Time in business
    • NAICS Code
    • Number of employees
    • Application method (e.g., in-person, phone, mail, online)
    • Application recipient (e.g., direct or through a third party)
    • Reasons for denial (providing nine specific reasons and a text box for any other reason)
    • Number of principal owners (i.e., 0-4)

    The SBREFA Outline envisioned the first four above; the last four were introduced in the proposal. Of particular note, pricing data is granular: for fixed-rate loans, the rate; for variable-rate loans, the margin, index value, and index name; for merchant cash advances and similar products, the difference between the amount advanced and the amount paid; and for all transactions, origination charges, broker fees, whether the fees were paid directly to the broker or to the financial institution for delivery to the broker, noninterest charges imposed over the first year, whether the financial institution could have included a prepayment penalty under its policies, and whether it did impose a prepayment penalty.

    Will everything be published?

    Lenders must collect and report to the Bureau annually, which will publish the data on its website — subject to modifications or deletions that it determines advance a privacy interest. The Bureau has not yet proposed modifications or deletions, but intends to issue a policy statement on its approach after it has received one full year of data.

    In the meantime, however, the Bureau has made clear that it will disclose the identity of financial institutions and is generally not persuaded that competitive or reputational harms to financial institutions or increased litigation are a basis to withhold publication of data. Instead, the Bureau has indicated that its principal concern is avoiding the risk that an applicant could be re-identified through specific data points.

    How will the rule impact small business lending?

    The proposal would apply to thousands of small business lenders offering a wide range of products. The Bureau acknowledges the collection and reporting of this information will impose costs on lenders, some of which it expects to be passed along to borrowers.

    But the most significant impact of the rule will be the Bureau’s eventual publication of the data. In its view, publication of granular data on specific lending decisions will advance the statutory goals of facilitating fair lending enforcement and business and community development. But concerns over reputational harms and increased fair lending scrutiny may also cause lenders to eliminate subjective elements of underwriting that are a traditional, and often appropriate, feature of small business underwriting. If the eventual effect of the rule is to, as one commenter put it, “artificially flatten prices,” the rule could lead to a small business lending market that is less innovative and less sensitive to actual credit risk than the market that exists today.

    The public has 90 days to submit comments regarding the CFPB’s proposal.

    If you have any questions regarding the CFPB’s proposed rule, please visit our Fair Lending and Fair Servicing page or contact a Buckley attorney with whom you have worked in the past.


    [1] The proposal would exclude certain other types of credit, including trade credit, public utilities credit, securities credit, and incidental credit. The rule would also not cover factoring, leases, consumer-designated credit used for business purposes, and credit secured by certain investment properties (specifically 1-4 individual dwelling units).

    [2] A principal owner is any individual who owns 25% or more of the small business.

    [3] If not feasible, the institution must provide notice to the applicant of its intention to share this information.

    Federal Issues CFPB Special Alerts Consumer Finance 1071 Small Business Lending

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