The Consumer Financial Protection Bureau (CFPB) issued a filing instruction guide for those lenders who must submit small-business lending data beginning in 2024.
The guide is for lenders who will be filing data from Oct. 1, 2024, to Dec. 31, 2024, in 2025. Staff who collect, prepare, and submit data; technology support staff, and compliance offers should find the guide helpful, the bureau stated.
According to the guidance, the data will be submitted through a web interface to the CFPB’s platform. Each filer will need to provide financial institution-identifying information and an authorized representative will need to certify the accuracy and completeness of the data submitted.
The files should be in comma-separated values (CSV) file format, and should adhere to the following standards:
- The register must be a comma-delimited text file.
- The first line of the file is a header row. The contents of the header row must be the column names specified in the data points section of the guide, in the order of the field numbering used in the guide, separated by commas.
- Each following line of the file represents a covered application record. Each record in the file must contain the data fields described in the data points section of the guide, in order, corresponding to the order of the column names in the header row.
- Each data field within each row must be separated with a comma. That means that if you leave a field blank, the field should still be denoted by commas (example: three fields containing 1, [blank], 3 would be formatted as 1,,3).
- If any field contains space(s) before and/or after the comma delimiter, the space(s) will be ignored.
- This is not a fixed-width formatted file. Do not include leading zeros, tabs, or spaces for the purpose of making a data field a specific number of characters.
- If a field contains a comma character, the field must be enclosed in double quotes (e.g., “Confederated Tribes of the Coos, Lower Umpqua and Siuslaw Indians of Oregon”). Fields not containing a comma can also be enclosed in double quotes, but this is not required.
- No field in a row may contain a line break, newline, or carriage-return. Line breaks should only appear at the end of a row. Each row of the file should represent a whole application record.
- Files must use UTF-8 encoding (note that all-ASCII files are always valid UTF-8).
The data points that need to be included are: the loan’s unique identifier, application date, application method, application recipient, credit type, credit purpose, the amount applied for, the amount approved or originated, what actions are taken, the dates of those actions taken, denial reasons, pricing information, census tract, and gross annual revenue.
The bureau makes the point that while the guide goes through these and many more, the list is not exhaustive, and entities required to file Section 1071 small-business lending loan data should check the regulation for a complete list of data points.