The Center for Responsible Lending, The Leadership Conference on Civil and Human Rights, the League of United Latin American Citizens (LULAC), Legal Defense Fund, and National CAPACD - National Coalition for Asian Pacific American Community Development submitted a comment letter yesterday to the Consumer Financial Protection Bureau that opposes the CFPB’s Notice of Proposed Rulemaking (NPRM) that would delay and narrow the 2023 rule implementing Section 1071 of the Dodd-Frank Act. 1071 is one of the most significant civil rights since the passage of the Equal Credit Opportunity Act (ECOA), designed to help detect discrimination and identify unmet credit needs in small business lending — especially among women and those from Asian American and Pacific Islander, Black, Latino/Hispanic, Native American, and other historically marginalized communities. The comment argues that efforts to exempt a majority of lenders from reporting, exclude certain loan products from coverage and eliminate pricing information are against statutory intent. It also argues that the CFPB’s cost benefit analysis fails to meet the appropriate standard.
