CFPB Extends Compliance Dates for Small-Business Lending Rule

Posted by Gracie Nelson on July 2, 2024

Introduction 

On June 25th the Consumer Financial Protection Bureau (CFPB) announced a significant extension of compliance deadlines for its small-business data collection rule. This interim rule provides lenders with more time to prepare amidst legal and regulatory changes.  

While the extension primarily impacts the timeline and implementation phases for the small-business lending rules, it also allows for a coordinated approach in preparing for compliance with comprehensive data collection requirements outlined in the 1071 rules, which specifically mandate the collection and reporting of data on small business lending.  

Detailed Impacts and What to Expect 

Timeline Adjustment:  The extension of 290 days for compliance deadlines allows lenders more time to prepare and implement systems for data collection under the 1071 rules: 

• Lenders originating 2,500 or more small-business loans annually must commence data collection by July 18, 2025. 

• Lenders originating at least 500 loans annually have until January 16, 2026, to commence data collection. 

• Lenders originating a minimum of 100 loans annually must commence data collection by October 18, 2026. 

Beta Testing and Preparation: The CFPB is beta testing phase for the data submission platform, scheduled to begin in August, aligns with the revised timeline. This phase will allow lenders to test their systems and processes for compliance with both the small-business lending rules and the specific requirements of the 1071 rules. 

Compliance: During the initial phase of data collection, which includes the extended deadlines, the CFPB has indicated a lenient approach to penalties for reporting errors. 

Conclusion 

The CFPB’s extension of compliance deadlines for small-business lending rules marks a pivotal step in accommodating financial institutions in the shifting regulatory landscape. This extension provides crucial additional time for lenders to align with the comprehensive data collection requirements mandated by the 1071 rules and to maintain important member protections.  

The association weighed in on this rule while it was in development and asked for a tiered implementation which was included in the final rule. GoWest also had a member participate on the SBREFA Panel in the early stages of the development of this rule. 

Posted in Advocacy on the Move, Regulatory Advocacy.