The bureau is seeking information in five broad categories: the definition of a small business; the data points the bureau should require banks to report; the lenders to be encompassed by the data collection; the financial products offered to small businesses; and privacy and confidentiality concerns related to the data collection. Comments are due July 14, 2017, and ABA is forming a working group to help respond to the request.
ABA has previously called on Congress to repeal Section 1071, noting that its conflation of consumer and commercial lending is misguided. Furthermore, ABA noted in its analysis that the CFPB has no experience or institutional proficiencies to meet the requirements for gathering information on small business and understanding commercial lending.
Read ABA's staff analysis

Read the request for information.
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