The American Financial Services Association (AFSA), Consumer Bankers Association (CBA), CRE Finance Council (CREFC),3 Equipment Leasing and Finance Association (ELFA), Mortgage Bankers Association (MBA), National Association of Federally-Insured Credit Unions (NAFCU), Truck Renting and Leasing Association (TRALA), and the U.S. Chamber of Commerce (Chamber)(together, the “Trades”) write to urge action by the CFPB to address the current disparity that exists for financial institutions working to implement the CFPB’s Small Business Lending Data Collection Rule (the “1071 Rule”). Some of these trade associations have also written to you individually
