ICBA Urges Community Bank Exemption from New Small Business Reporting Mandate

Sep 14, 2017
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Washington, D.C (Sept. 14, 2017)—The Independent Community Bankers of America® (ICBA) today called on the Consumer Financial Protection Bureau (CFPB) to use its authority to exempt community banks from new data-collection and -reporting requirements on small business lending. The reporting mandates required under Section 1071 of the Dodd-Frank Act would disproportionately affect community banks’ small business lending, ICBA wrote in response to the CFPB’s request for information.

“Imposing data collection requirements on community bank small business lending will significantly degrade the ability of community banks to offer small businesses the type of credit they need in a timely and economically efficient manner,” ICBA wrote. “The cost of this new mandate will be disproportionately high for community banks that simply do not have the scale to spread compliance costs over a large asset base and will result in negatively impacting those the statute is trying to help—women-owned, minority-owned and small businesses.”

ICBA noted in its letter that community banks are outsized small business lenders and take their fair lending obligations seriously. However, the standardized collection process called for by Section 1071 of the Dodd-Frank Act would clash with the individualized nature of community bank small business lending, requiring a homogenized approach that would reduce access to credit for businesses with unique needs. Further, the collection and public disclosure of personal data raises concerns about the privacy of small business applicants, particularly in smaller communities, ICBA wrote.

In addition to asking the CFPB to continue its outreach to stakeholders affected by this rulemaking, ICBA continues calling on Congress to repeal Section 1071, as advocated by the Treasury Department. An outright repeal would avoid higher borrowing costs, a reduction in access to credit, and inadvertent harm to the small businesses the law is intended to help.

About ICBA
The Independent Community Bankers of America®, the nation’s voice for more than 5,700 community banks of all sizes and charter types, is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education and high-quality products and services. For more information, visit ICBA’s website at