AFSA Submits Comment Letter on Small Business Lending Data Collection Proposal
Earlier this week AFSA submitted comments on the CFPB’s proposal to change small business lending data collection requirements established under Section 1071 of the Dodd-Frank Act (the 1071 Rule). This proposal contemplates streamlining data collections and establishing a simplified compliance date structure applicable to all affected lenders. The proposed compliance date will be January 1, 2028.
AFSA was engaged on this issue even before the first 1071 Rule proposal was issued in 2021. With input from members, we have consistently sought simplification of data collection and reporting obligations. We have also asked for exclusions from coverage by the 1071 Rule for indirect vehicle finance transactions, floorplan financing, merchant-initiated credit applications, and other forms of credit offered by AFSA members.
The CFPB is currently operating in an unusual manner, as the leadership has announced that the agency lacks funding to continue normal operations. This raises some questions about how quickly the CFPB will finalize its review of comments and preparation of final rulemaking on this subject. We understand the CFPB may choose to issue an interim final rule on an expedited basis in order to wrap this up before becoming insolvent.
AFSA will continue to monitor developments.
December 17th, 2025
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