Before developing ECOA data collection rule, bureau collecting data on cost of collecting data

A survey designed to collect information about the one-time costs for preparing to gather and report data about applications for credit made by women-owned, minority-owned and small businesses is being conducted by the federal consumer financial protection agency.

In a letter sent this week to financial institutions, the Consumer Financial Protection Bureau (CFPB) said its “small business compliance cost survey” seeks information from those institutions which offer small business credit products that could be covered by the Equal Credit Opportunity Act (ECOA).

The act was amended by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) 10 years ago to require that information about applications for credit made by the women-owned, minority-owned and small businesses be compiled, maintained and then reported to CFPB. Overall, the agency said, 13 separate data points are required to be collected and reported.

The agency said the survey will gather information about the one-time costs of preparing to collect and report the information from institutions that offer small business credit products that could be covered by the rule. CFPB said it is beginning to develop the regulation required by the Dodd-Frank legislation – but that no policy decisions have been made about institutions and products to be covered, or the data points to be reported. (The law does allow CFPB to add data points to those required under statute.)

On July 29, CFPB is hosting an on-line symposium to discuss the use of cost-benefit analysis in consumer financial protection regulation. In making the announcing, the agency said the event is part of an overall effort to consider how to employ cost-benefit analysis as it develops regulation. The agency said the symposium would look at “developments in the cost-benefit analysis arena” and that the agency would also consider “lessons that may be useful as it nears the start of its second decade of work.”

Small business compliance cost survey

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