Small Business Lending Data Collections Comments
OLA filed comments regarding the collection of small business lending data as prescribed under Section 1071 of the Dodd-Frank Act, which amended the Equal Credit Opportunity Act (ECOA) to require lending entities to submit to CFPB data on credit for women-owned, minority-owned, and small businesses. OLA’s comments focused on having flexible definitions that are clear and easy to administer, balancing the need to have data point collections that meet statutory requirements without stifling innovations, and the having policies in place that limit potential exposure of data that could lead to security breaches.
Read the full comment here.
OLA Comment: Proposed Interagency Guidance on Third-Party Relationships: Risk Management Docket No. Op-1752