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ICBA this week began calling on community bankers to submit personalized comments on the Consumer Financial Protection Bureau’s proposal to implement Dodd-Frank Section 1071 collection and reporting requirements.
Submitting Comments: Because the CFPB does not consider form letters, ICBA offers a comprehensive guide to help community bankers develop, format, and submit personalized comments unique to their bank and community.
Background: Dodd-Frank Section 1071 requires financial institutions to collect and report data on credit applications from certain small businesses, which would restrict access to credit, raise borrower privacy concerns, and require costly new third-party relationships.
ICBA Position: ICBA is strongly advocating a robust community bank exemption and other reforms, as laid out in ICBA’s comment letter guide.