The American Bankers Association this week offered feedback to the Consumer Financial Protection Bureau on a survey intended to gauge the potential one-time costs associated with preparing to collect and report data on small business lending, as required by section 1071 of the Dodd-Frank Act. ABA—which has long raised concerns about small business data collection—emphasized the need to fully understand not just the implementation costs but also the ongoing compliance costs, which it cautioned would likely increase the cost of credit for small business borrowers.
Regarding the survey itself, ABA said that the CFPB’s estimated completion time of 30 minutes was too low. The association noted that small business lending tends to be conducted by various lines of business and systems within a bank, making it challenging to accurately respond to several questions in the survey, such as those involving the number and dollar amounts of originations of various credit products. ABA also offered specific comments on several of the individual survey questions.
