The American Bankers Association (ABA) is surveying banks on the costs of implementing the Consumer Financial Protection Bureau's (CFPB) proposed section 1071 rule (small business data collection). This survey collects information on the one-time costs of preparing to collect and report the 1071 data, as well as the ongoing costs of collecting and reporting the data once the 1071 rule is in effect.
We encourage your bank to participate in this important survey. Answering the questions in the survey will help us formulate a comment letter to the CFPB explaining the impact of the 1071 rule, including, but not limited to, the impact on small banks and on small businesses themselves. The CFPB's estimates of one-time costs were based on a survey of only 100 respondents which was issued before the proposed rule was released, so respondents did not know how broad the rule's scope would be or how many data points would be required. The CFPB based their estimate of ongoing costs on the costs of reporting Home Mortgage Disclosure Act (HMDA) data; we believe there are important differences between mortgage lending and small business lending that require a different assessment of ongoing costs of implementing the 1071 rules.
Please designate a survey coordinator for your institution, if at all possible, so that only one, coordinated response from your institution is received. If you are not able to respond to a question, or if it does not apply to your bank, please skip it, and continue with the rest of the survey. Be assured that all financial institution data will be kept confidential.
The survey questions are available here for your reference, however, please note that to respond to the survey you must use this link. Please complete the survey by Monday, Nov. 22.
Complete the Survey