HOPE Submits Public Comment on Proposed Revisions to Small Business Data Collection Rule
December 19th, 2025
HOPE submitted a public comment to the Consumer Financial Protection Bureau (CFPB) in response to the agency’s proposed revisions to the 2023 final rule implementing Section 1071 of the Dodd-Frank Act, which requires financial institutions to collect and report small business lending data under the Equal Credit Opportunity Act (ECOA).
Section 1071 was designed to bring transparency to the small business lending market. particularly for businesses owned by people of color, women, and other historically underserved groups. In this proposed revision, the CFPB is dramatically narrowing the scope of small business data collection, obscuring significant parts of the marketplace and potentially rendering it ineffective in carrying out the statutory purpose of Section 1071.
HOPE encourages the CFPB to retain the spirit of Section 1071 by:
- Providing expansive coverage of lenders, products, and small businesses;
- Collecting essential data to ensure fair lending; and
- Publishing accessible, disaggregated data.
These recommendations are informed significantly by HOPE’s lending practices and data. HOPE’s experience demonstrates that key data can be obtained in a reasonable manner and that the benefits of data collection far outweigh any related costs. With these recommendations, the CFPB can provide an even playing field for both lenders and borrowers and strengthen the intent of Section 1071 which is to provide a more robust marketplace and stronger economy.
Section 1071 must include the appropriate guard rails to ensure a fairer marketplace. With the appropriate coverage and scope, the proposed rule will quantify and make transparent the extent to which financial institutions serve business owners of color and other marginalized groups.
In an increasingly diverse nation, closing the small business capital gap is key to building a robust, equitable economy.
Read HOPE’s full comment is available here.
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