NEWS: The CFPB has announced the availability of the beta platform for its small business lending data collection rule.
Background
As we explain in The League’s ii Release No. B083, the CFPB’s small business lending rule is part of Reg. B, which implements the federal Equal Credit Opportunity Act. Starting in 2025, the rule will require certain credit unions to collect and report data about loans to small businesses.
The rule applies to any entity (including a credit union) that engages in any financial activity and that originated at least 100 loans to “small businesses” in each of the two preceding calendar years. A credit union of any asset size may be subject to the rule.
A “small business” is one that had $5 million or less in gross annual revenue for its preceding fiscal year. Extensions of credit to larger businesses do not count for the purposes of this rule.
The CFPB’s new platform
The CFPB said that it invites financial institutions and their technology partners to test the beta platform for lenders to report their small business lending data. Participants can create a Login.gov account, upload sample data test files, review validation results, and explore the beta platform’s features, then they can share feedback with the CFPB about their experiences.
That feedback will help the CFPB identify areas for potential enhancement and improve the data filing process. Teams can work in an early test environment at their own pace and convenience.
To access the beta for the Small Business Lending Data Filing Platform, visit https://sbl-beta.cfpb.gov/. To learn more about the beta platform and how to get started, review this document.
Please note that the beta platform is for testing purposes only. Data submitted on the beta platform will not be considered for compliance with small business lending data reporting requirements. Test files to be used can be found in the CFPB’s test file repository. Participants are welcome to test using other sample files; however, it is imperative that they do not use actual customer data.
The CFPB said that it encourages participants to provide feedback on their experience using the beta for the Small Business Lending Data Filing Platform and to direct any questions regarding the platform to SBLHelp@cfpb.gov.
A reminder on compliance deadlines
In a May Compliance Courier, The League informed you about CFPB guidance that pushed back the compliance deadlines for this rule. (Compliance had been required as early as October 2024, but the CFPB pushed back the deadlines for this rule, so that the soonest some credit unions will have to begin collecting data and complying with the rule is July 2025.) The CFPB formalized that guidance in an interim rule this summer.
The rule will take effect in stages, depending on which of three “tiers” a lender is in, with the largest-volume lenders having to comply sooner.
The CFPB’s “Small Business Lending Rule Info Sheet” provides flow charts and examples to help you determine whether and when your credit union may need to comply with this rule. It includes this table to explain the compliance deadlines: