CFPB Released FAQs for Small Business Data Collection and Reporting

On June 28, 2023, the CFPB released a set of Frequently Asked Questions to address for determining institutional coverage focused on areas like:

  • Financial Institution Coverage
  • Metropolitan Statistical Areas (MSA)
  • Types of transactions
    • Ag purpose credit
    • Refinancings
    • Temporary loans
  • What to do if you did not collect Gross Annual Revenue for 2022 and 2023
  • Covered Credit Transactions and Small Businesses
    • Covered credit transactions
    • What is a small business
    • Individuals and sole proprietorship

The purpose of the FAQs is to help financial institutions determine if they are a covered institution and to properly count transactions for determination of their compliance tier. Additionally, they clarify business entity types specifically for individuals, sole props, and start-ups.

If your institution has determined your tier or are still in the process of trying to create a good methodology for tier determination it would be beneficial to review these FAQs to ensure your methodology aligns with the CFPBs guidance.