As promised (and discussed here), the Consumer Financial Protection Bureau (CFPB) issued its final rule under Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Final Rule). Section 1071 amended the Equal Credit Opportunity Act (ECOA) to impose significant data collection requirements on small business creditors. According to the press release announcing the Final Rule’s issuance, “[l]enders will collect and report information about the small business credit applications they receive, including geographic and demographic data, lending decisions, and the price of credit.”








