•      "The final rule will force lenders to standardize loan terms and limit options to the detriment of borrowers, including minority- and women-owned businesses. Instead of accommodating community banks and their customers, the final rule mandates the collection of eight additional data points not required by statute. The breadth of the data required to be collected and potentially published may make it possible to identify individual borrowers thereby compromising their financial privacy. Moreover, the mandated data collection will increase compliance costs for community banks and result in a higher cost of credit for small business borrowers who are already struggling with historic inflation, higher interest rates, and a possible recession." Source: Rebeca Romero Rainey, President & CEO of Independent Community Bankers of America

•     "While industry fully supports complying with the nation’s fair lending laws, the enormity of the data points to be collected and the 100-loan threshold for determining which lenders must report means compliance with this new ruling will place significant burden on banks, especially community banks. Defining a small business as one with gross annual revenues of $5 million or less expands the rule to cover medium and larger businesses, going beyond what Congress intended. Additionally, the final rule states that the CFPB has not decided what vehicle it will use to make privacy determinations but does not believe it is legally required to go through a public rule-making procedure to determine whether and how data will be redacted prior to publication." Source: Kirsten Sutton, American Bankers Association