Small Business Loan Reporting
The CFPB’s small business loan reporting final rule excludes HMDA reportable loans, but not all commercial investment property. Some MBA members may be required to collect and report data on commercial real estate loans.
On October 8, 2021, the Consumer Financial Protection Bureau issued a proposed rule under § 1071 of the Dodd-Frank Act. Section 1071 of the Dodd-Frank Act requires the Bureau to issue rules to implement requirements to report on lending to small businesses, particularly minority- and woman-owned businesses.
On March 30, 2023, the Bureau released its small business loan reporting final rule which may require some MBA members to collect and report data on commercial real estate loans. The final rule excludes HMDA reportable loans and provides implementation timelines ranging from eighteen to thirty-three months. The Bureau has also provided materials and tools to help explain data requirements and filing instructions that can be found here.
Read our summary comparison chart showing differences between the proposed and final rule.
Recent MBA Activity Related to Small Business Loan Reporting
Related MBA Events
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Commercial/Multifamily Finance Convention and Expo -
Commercial Real Estate Basics: Borrower Mortgage Credit and Financial Statement Analysis: February 2025
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School of Multifamily Property Inspections: February 2025: Atlanta
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Commercial Real Estate Basics: Introduction to Commercial/Multifamily Real Estate: March 2025: On Demand
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Commercial Real Estate Basics: Appraisal and the Three Approaches to Value: March 2025
