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Association Comments on CFPB’s Proposed Revisions to Section 1071 Rule

The MD|DC Credit Union Association recently submitted a comment letter to the CFPB regarding proposed revisions to Regulation B under Section 1071 of the Dodd-Frank Act which governs how financial institutions collect and report small business lending data.

The Association supports increasing the reporting threshold from 100 to 1,000 small business loan originations. This adjustment would exempt many smaller and community-based credit unions from the rule’s reporting requirements, significantly reducing compliance costs while still capturing more than 90 percent of small business lending activity.

The CFPB is also proposing to narrow the definition of a small business by lowering the gross annual revenue threshold from $5 million to $1 million. Aligning this definition with existing regulatory standards would simplify compliance processes and reduce the likelihood of classification errors. Additionally, the Bureau plans to eliminate several discretionary data points, easing operational demands during early implementation.

MD|DC Credit Union Association President and CEO John Bratsakis noted, “The proposed changes to the Section 1071 rule represent a significant step toward reducing regulatory burden and improving data quality for credit unions. We appreciate the realistic approach taken by this rule, and the consideration of how it affects lenders that serve every community.”

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