The Equipment Leasing & Finance Association (ELFA) joined with five national trade associations to submit a comment letter to the Consumer Financial Protection Bureau (CFPB) on proposed revisions to Regulation B, specifically the small business lending rule under the Equal Credit Opportunity Act (ECOA). The co-signatories are America’s Credit Unions, Association of Equipment Manufacturers, Consumer Bankers Association, Innovative Lending Platform Association and the U.S. Chamber of Commerce.
“ELFA has worked closely with the CFPB for more than a decade to ensure that its rulemaking achieves its intended protections without putting undue regulatory burdens on our industry and the wider U.S. business community,” Leigh Lytle, president and CEO of ELFA, said. “We appreciate the support of our trade association partners in our efforts commenting on the rulemaking, and stand ready to engage further to ensure that the final rule meets statutory objectives without unintended consequences for small business credit access.”
The comment letter commends the CFPB on its proposal to promote fair access for small businesses, including those owned by women and minorities, while reducing unnecessary complexity and compliance burdens that could otherwise restrict credit availability. The provisions include:
- Narrowing the revenue threshold from $5 million to $1 million to recognize the smallest enterprises — those most vulnerable to credit barriers and most critical to local economic growth.
- Focusing on data points specified by Congress and eliminating unnecessary reporting fields to strike the right balance between transparency and operational feasibility.
The associations’ comment letter also provides recommendations to the CFPB on provisions related to:
- Vendor-dealer, indirect lending and broker-facilitated transactions
- Compliance threshold and lookback period
- Private label and point-of-sale credit
