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SFNet Requests Feedback on CFPB 1071
November 19, 2020
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:
QUESTIONS
- In a couple of sentences, please explain why CFPB 1071 should not apply to your industry/organization:
- In a couple of sentences, please explain why your organization could not comply with CFPB 1071 (if applicable):
- Are there specific classes of credit providers that we should focus on e.g. ABL Lenders, leasing companies, factors, others?
- With the types of providers we focus on are there specific rationales for either exclusion or limitation on scope and what are they?
- Should we adopt a dollar threshold to define small business (e.g. only below $500,000 in gross revenue)?
- Should we consider advocating data collection after a transaction is closed or abandoned?
- Should we make a distinction between large credit providers and small ones?
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