WBA-member banks are asked to participate in the American Bankers Association’s survey of the costs of implementing the CFPB’s proposed section 1071 rule (small business data collection). This survey collects information on both the one-time costs of preparing to collect and report the 1071 data, as well as the ongoing costs of collecting and reporting the data once the 1071 rule is in effect.
We encourage your bank to participate in this important survey. Answering the questions in the survey will help us formulate a comment letter to the CFPB explaining the impact of the 1071 rule, including but not limited to the impact on small banks, and also on small businesses themselves. The CFPB’s estimates of one-time costs were based on a survey of only 100 respondents which was issued before the proposed rule was released, so respondents did not know how broad the rule’s scope would be or how many data points would be required. The CFPB based their estimate of ongoing costs on the costs of reporting HMDA data; we believe there are important differences between mortgage lending and small business lending that require a different assessment of ongoing costs of implementing the 1071 rules.
Be assured that all financial institution data will be kept confidential. If you are not the correct contact for this survey, please forward this request to your bank’s subject matter experts for consideration. We apologize to those of you who are members of more than one related working group as you are probably receiving this survey more than once — as noted below, please only send one response.
Please designate a survey coordinator for your institution, if at all possible, so that we receive one coordinated response from your institution. If you are not able to respond to a question, or if it does not apply to your institution, please skip it, and continue with the rest of the survey.
Access and complete the survey here. Please respond by Wednesday, December 1.
Thanks in advance for your cooperation. If you have questions, please contact Kitty Ryan.