“America’s banks oppose discrimination in any form and support enforcement of fair lending laws and the goals of Section 1071. Banks of all sizes have a long history of lending to creditworthy small businesses across the country, and ABA supports bank efforts to lend to underserved small businesses.
“While today’s final rule implementing Section 1071 includes a few of our recommendations for the proposed rule, we are disappointed that it remains unnecessarily far-reaching and will harm the relationship banking model Director Chopra often praises – the model that community banks have relied on to meet the unique needs of small businesses in their communities.
“Given the cost of implementing these significant new reporting requirements and their impact on lending, some community banks may be forced to limit their small business loan programs. Non-banks – many not supervised for compliance by the Bureau – may absorb some of the small business lending done today by banks, but they will not be able to offer their customers the benefits of a banking relationship and the technical assistance banks provide to their small business customers. We also worry that the data produced will put small businesses’ privacy at risk and could provide an incomplete and potentially misleading picture of small business lending to underserved groups. These outcomes are not what Congress intended when it passed the Dodd-Frank Act back in 2010.”
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