SFNet Requests Feedback on CFPB 1071

In order to properly formulate SFNet’s response to the CFPB on Section 1071 of Dodd-Frank, which could prove to be unduly burdensome to the vast majority of small and mid-sized finance companies that provide credit to small businesses, it would be helpful to have feedback on the below questions from SFNet members.  Please send your responses to mocejo@sfnet.com by Friday, November 20.

For details on 1071:

https://www.sfnet.com/home/industry-data-publications/the-secured-lender/magazine/tsl-article-detail/advocacy-alert-cfpb-section-1071-rule-could-place-burden-on-financial-institutions-action-required

QUESTIONS

1. In a couple of sentences, please explain why CFPB 1071 should not apply to your industry/organization:
2. In a couple of sentences, please explain why your organization could not comply with CFPB 1071 (if applicable):
3. Are there specific classes of credit providers that we should focus on e.g. ABL Lenders, leasing companies, factors, others?
4. With the types of providers we focus on are there specific rationales for either exclusion or limitation on scope and what are they?
5. Should we adopt a dollar threshold to define small business (e.g. only below $500,000 in gross revenue)?
6. Should we consider advocating data collection after a transaction is closed or abandoned?
7.  Should we make a distinction between large credit providers and small ones?