Statement: CFPB 1071 Data Collection Proposal
Statement by Luz Urrutia, CEO of Accion Opportunity Fund, the nation’s leading CDFI, nonprofit small business lender, on the Bureau’s proposed guidelines to collect data on small business lending
Consumer Financial Protection Bureau on the Right Track To Promote Transparency in Small Business Credit Markets
San Jose, Calif., Jan 5, 2022— I am encouraged by the guidelines the Consumer Financial Protection Bureau (CFPB) has issued to fulfill its congressional mandate (section 1071 of the Dodd-Frank Act) to collect small business lending data on how much is being lent to small businesses and who is receiving the funding. This action is long overdue.
Accion Opportunity Fund commends the Bureau for issuing such thoughtful and comprehensive guidelines, and offers a few additional considerations to ensure the agency delivers the best data and transparency possible to help the nation understand which small business owners are and are not able to access fair and affordable credit. While disparities in small business lending and the racial wealth gap are well-documented, there is currently no single comprehensive data set available to analyze trends within the industry. This is especially concerning when, even prior to Covid, an estimated $87 billion of unmet capital needs existed among small business owners. Section 1071 would help encourage the market to address gaps in small business financing and the rise in irresponsible lending. Properly implemented, section 1071 could also be a model for a market-based, pro-innovation approach to regulation.
We appreciate the Bureau’s extensive research and analysis in proposing these guidelines. To further strengthen section 1071, we urge the Bureau to:
- Increase its proposed gross annual revenue threshold for a covered small business to $8 million and include factoring and leases as covered products.
- Require pricing reporting of annual percentage rate (APR), the only means of comparing financing products across varying terms.
- Collect data on disability status and LGBTQ+ status.
- Require the reporting of credit scores.
Based on our own experience and those of similar lenders, the costs to comply with the data reporting guidelines set forth will not be a constraint. The mortgage industry, through the Home Mortgage Disclosure Act (HMDA), has already managed to implement similar data collection while building a successful recovery from the meltdown of the Great Recession. HMDA did not lead to increased interest rates for mortgages; rather, they have been at historic lows for years. The commercial lending sector can also come together to report data on their activities.
We cannot manage what we cannot measure. I commend the Bureau for issuing such comprehensive and helpful guidelines to fulfill its mandate to collect data on our nation’s small business credit markets. I urge the Bureau to move quickly in publishing the final rules.
To request an interview with Luz Urrutia, contact Caitlin McShane at (415) 225-8855 or firstname.lastname@example.org.
About Accion Opportunity Fund
Accion Opportunity Fund works to create an inclusive, healthy financial system that supports the nation’s small business owners by connecting entrepreneurs to affordable capital, educational resources, coaching, and networks. Through innovative partnerships and outreach strategies, we reach entrepreneurs of color, low-income entrepreneurs, and women, who often lack access to the financial services they need to build and grow their businesses. Opportunity Fund Community Development is the lending arm of Accion Opportunity Fund, California Finance Lender license #6050609.