You are currently viewing Action Needed: Comment on Small Biz Lending Data Collection

Just two days remain for community banks to comment on proposed rules that will govern small business loan data collection under Section 1071 of the Dodd-Frank Act.

If you make more than 25 business loans per year, this rule applies to your bank.

In a year-end Call to Action issued last week, IBAT President and CEO Christopher Williston said, “we believe that Section 1071 rule implementation will result in more ‘formulaic’ and less ‘relationship based’ lending. This will result in reduced credit availability for start-up and marginally capitalized entities, bearing a negative impact on community banking and small businesses nationwide.”

“We have seen a 37.2% decline in the number of bank charters in the United States over the last decade,” Williston said. “We believe that the implementation of Section 1071 of Dodd-Frank will further exacerbate the deterioration of community banking by undermining the unique nature of small business lending.”

From a review of the comment letters filed to date, too few banks have taken action in response to this proposal. Prior to the January 6 deadline to file comments, we encourage you to:

  1. Review IBAT’s comment letter, filed on December 27.
  2. Utilize ICBA’s guide to commenting on Section 1071 rules to craft your own letter.