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AFSA Submits Comment Letter on Small Business Lending Data Collection Proposal

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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.

AFSA Submits Comment Letter on Small Business Lending Data Collection Proposal
Dec 17, 2025

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 streamliningRead the rest

AFSA Supports Major Bipartisan Housing Legislation
Dec 17, 2025

AFSA is pleased to support the bipartisan Housing for the 21st Century Act, which will boost housing supply, improve affordability, and streamline existing regulations for millions of Americans.

Thanks to House Financial Services CommitteeRead the rest

AFSA C3 Index
Dec 11, 2025

AFSA’s Consumer Credit Conditions (C3) Index for the third quarter of 2025 revealed a challenging quarter for consumer lenders offset by growing optimism about business conditions over the next six months. The survey of AFSA member companies… Read the rest

CFPB Funding
Dec 11, 2025

In a new letter to President Trump and congressional appropriations committee leaders, the CFPB’s Acting Director Russell Vought wrote that the Bureau will need $279 million next year to maintain its required activities. Read the rest

Industry Expertise | How Lenders Can Innovate with AI Without Increasing Regulatory Risk
Dec 10, 2025

Industry Expertise” is sponsored content produced by AFSA’s Business Partners’ to provide thought leadership and best practices for AFSA member companies. For more information about this sponsored content opportunity, contact Dan Read the rest

AFSA in American Banker
Dec 09, 2025

We appreciate the American Banker’s coverage of our exclusive Consumer Credit Conditions (C3) Index, which we release quarterly.

The C3 Index is designed to highlight the crucial role the consumer credit industry plays in the broader

Read the rest

AFSA Economist Shares Thoughts on Economic Outlook
Dec 03, 2025

AFSA Chief Economist Tim Gill recently took part in a panel discussion on economic and automotive industry trends at Used Car Week 2025. The panel “Inside Automotive & the Economy,” was moderated by Nick Zulovich of Cherokee Media Group… Read the rest

A New CFPB Nomination
Nov 20, 2025

Clarity and certainty in the public policy space has long been a priority for the American Financial Services Association, which is why we appreciate the recent nomination of Stuart Levenbach to serve a five-year term as director of the Consumer… Read the rest

THIS THURSDAY | AFSA Webinar | How Leading Lenders are Automating for the Next Demand Surge
Nov 18, 2025

BUSINESS PARTNER WEBINAR
How Leading Lenders are Automating for the Next Demand Surge
November 20, 2025 AT 2:00 P.M. ET

As interest rates fall and demand accelerates, the most successful auto lenders are rethinking how they scale. In this

Read the rest

New AFSA Board Chair
Nov 13, 2025

Kevin Cullum, President, Nissan Motor Acceptance Corporation, will serve as the 2025-26 Chair of the American Financial Services Association Board of Directors. Cullum received the gavel from outgoing chair, Dan Walters, CEO of CreditRead the rest

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