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Small Business Loan Application Data Collection

Small Business Loan Application Data Collection

Tax laws should promote robust economic activity and a vibrant community banking sector and foster saving and investment. ICBA opposes any new bank-specific fees, punitive new tax levies, transaction taxes, limitations on the deductibility of FDIC premiums, or other proposals specifically targeting the financial services sector.

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Position & Background

  • As relationship bankers, community banks look at each small-business loan individually and often in customized terms based on many factors.

  • The CFPB’s rigid data collection requirements will hamper the ability of community banks to tailor loans to meet the unique needs of local businesses.

  • Not only will these data reporting requirements place a significant compliance burden on small community banks, but this final rule does not address the significant concerns ICBA has raised about the privacy of applicants, particularly in smaller communities.

  • The CFPB’s rule will make it possible for loan applicants to be identified, especially in rural areas — potentially driving small-business owners away from community banks and local communities while having a chilling effect on small-business lending.

  • The CFPB should use its authority to exempt more community banks and small businesses from its rule and limit mandatory data points to those required by statute. Restricting access to credit in local communities during this critical economic period will ultimately harm the borrowers the CFPB is trying to help — women-owned, minority-owned, and small businesses.

  • ICBA supports Congressional action to repeal the statute, or at a minimum, legislatively fix the most invasive and burdensome portions of the rule.

The CFPB finalized a rule for the collection and reporting of data on financial institutions’ small business lending under the Equal Credit Opportunity Act. This includes the collection of data that will be used to facilitate enforcement of fair lending laws.

While the governing statute requires the collection and reporting of 13 pieces of data, the CFPB is using its discretionary authority granted by statute to collecting an additional 8 categories of data, which comprise more than 80 datapoints and sub-data.

Letters & Testimonies

ICBA Expert Contacts

Mickey Marshall

Vice President, Regulatory Counsel
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michael_emancipator

Michael Emancipator

Senior Vice President, Regulatory Counsel
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Articles

SBA releases form to help community banks report on debanking compliance

As requested by ICBA, the Small Business Administration released a streamlined form to help community banks comply with President Donald Trump’s executive order on ensuring access to fair banking.

10/2/25  | 

SBA orders lenders to submit reports on debanking compliance

The Small Business Administration ordered the banks in its network to halt the practice of debanking certain individuals and businesses and to submit reports to the agency on their compliance with President Donald Trump’s executive order on fair banking.

8/28/25  | 

Senate confirms Bill Briggs as SBA deputy administrator

The Senate voted to confirm William Briggs as deputy administrator of the Small Business Administration.

7/10/25  | 

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