Program Overview

There has been a lot of activity around the new Small Business Lending Data Collection final rule that was issued by the CFPB last year, and it seems we have some resolution around whether we'll have to comply (Yes), and when (as the effective dates were revised); however, in the aftermath of the recent elections, the rule could be subjected to the Congressional Review Act by the next Congress. However, in the meantime, it is important to understand what this rule will do if it does not change. Time is of the essence. 

The rule will require lenders to collect and submit to the CFPB data around small business loan applications by June 1st of each year. No matter how this turns out, there is a transitioned implementation period, and when lenders must comply is based on how many small business loans they originate. This rule will have a dramatic impact on small business lenders' operations, and not just from an operational, and perhaps more importantly, a cultural, standpoint. There are significant cultural issues to address as well, as this will change, in significant ways, how small business applications are collected and processed.

In this webinar, we'll do a deep dive into the rule's current events and status, including when your bank may or must begin to collect and submit data. But our focus will not be a simple recitation of the rule, but how to effectively develop your implementation plan. We'll review the many issues so you can methodically ensure your program is on track. 
One of the many keys to determining the requirements is to understand the definitions involved, from “covered financial institution,” “covered origination,” and “covered credit transaction,” among others. We'll discuss precisely what a small business is, so you can zero in on which areas of the institution are affected by the requirements. We'll also examine the many data requirements  - what they mean, how they're defined, how to collect them, and ultimately submit them. This rule will exact a heavy load on the technology and automation functions of the institution, and we'll discuss some best practices in this area.

We'll also talk about what this data means from a fair lending standpoint, including the public nature of the information and some suggestions for fair lending analytics, as well as policy and procedure impacts. Join us for this in-depth discussion of the rule so you can best prepare for implementation, both operationally and technologically, and also culturally.
Even though the whole issue is up in the air a bit, lenders should not take this as a sign that the rule is going away. Far from it  - the extra time should be used to make sure things are right.

What You Will Learn

• Current status of the legal fight for implementation of the rule  - who is affected and what can we look forward to?
• The Final Rule itself  - where to find many helpful resources for compliance
• Differences between the proposal and Final Rule
• Who is covered? Examining the coverage thresholds and timing requirements, including the “transitional provision”
• Interplay between this rule, HMDA, and CRA reporting requirements
• Who is a “covered financial institution”?
• Determining what to report  - covered credit transactions and covered originations
• What types of applications are reported? How is an application defined for this purpose?
• Deep dive into the data points  - both those generated by the lender as well as those provided by the applicant
• Collecting demographic information  - forms, verifications, policies, procedures, and (fortunately) no responsibility to guess
• Submission requirements  - technology implications
• The “firewall” requirement  - ensuring lenders to not have improper access to the data
• Safe harbor and “bona fide errors” provisions
• The CFPB's Policy Guidance on supervisory and enforcement activities

Date & Time

July 15, 2025*

9:50AM Zoom Sign In | 10:00AM Webinar Start | 12:00PM Webinar Concludes

*NEW tentative date based on pending regulatory changes 

Who Should Attend?

Compliance Officers & Staff, Lending Officers, Small Business Lender