AFSA Comments on Small Business Lending Data Collection Compliance Dates
On July 18, 2025, AFSA submitted a comment letter to the CFPB regarding the compliance dates for the section 1071 rule on small business lending data collection. This rule has been subject to litigation, and the CFPB decided it was prudent to extend the compliance date for all covered lenders, thereby eliminating the different timelines for lenders who sued and those who did not. The CFPB has also publicly said that it intends to write a new section 1071 rule in the near future.
ASFA commented on this proposal to agree that establishing new compliance dates is a good idea. That being said, we took the opportunity to remind the CFPB of our past comments on its section 1071 rule and encourage the CFPB to take a measured approach with the new rule it is planning.
July 23rd, 2025
