Call to Action

The CFPB (Bureau) issued a Request for Information Regarding the Small Business Lending Market that was published in the Federal Register on May 15, 2017. Based upon comments received, the Bureau extended the comment period to September 14, 2017.

At issue is Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) that amends the Equal Credit Opportunity Act (ECOA) to require financial institutions to compile, maintain, and report information concerning credit applications made by women-owned, minority-owned, and small businesses.

There are nine specific “data points” that financial institutions must compile and maintain, submit annually to the Bureau, and make available to members of the public upon request.

IBAT believes that this reporting requirement is the epitome of regulatory burden and has the potential to signficantly harm Texas community banks.  With this concern in mind, there are three actions we're asking of IBAT member banks on this issue:

  1. IBAT has prepared a draft version of its comment letter on this issue. We ask that you review our comments and provide any additional feedback on how the proposed rule will affect your customers and/or your willingness to make small business loans.  If you would like to include some non-attributable quotes for us to include in our comment letter, please feel free to do so.  Please send all comments to Kelly Goulart at
  2. We encourage all IBAT members to file a comment letter of their own before the September 14, 2017 deadline. You can now file your comment letter online, via IBAT's Grassroots Action Center.  Instructions can be found on the Grassroots Action Center page.
  3. IBAT is also encouraging the passage of legislation that would address this issue. Click here to contact your Congressional representatives and register your support for the House version of the CLEAR Relief Act, H.R. 2133. You'll also have the option of submitting a letter of support for the Senate version of the CLEAR Relief Act, S. 1002 which does not currently address this issue.

If you have any question or concerns, please contact Chris Williston at or 512-474-6889.