The CFPB announced the availability of its beta platform for the small business lending data collection rule pursuant to section 1071 of the Dodd-Frank Act.
The CFPB has invited financial institutions to test the platform by uploading and using test files provided in the CFPB’s test file repository, or by uploading the financial institution’s own test or sample files. However, the CFPB notes that it is imperative that test files or samples do not contain actual customer data. The data submitted on the beta platform will not be considered for compliance with small business lending data reporting requirements, and can be removed from the platform at any time.
In order to begin using the testing platform, the following steps must be taken by the employee responsible for filing reports:
- Confirm the financial institution has a Legal Entity Identifier.
- Create an account with Login.gov using a financial institution email address. Personal email addresses will not be accepted.
- Select the financial institution for which the employee is authorized to file reports.
The CFPB requests feedback regarding use of the Small Business Lending Data Filing Platform and any questions regarding the platform be sent to SBLHelp@cfpb.gov.
As a reminder, the CFPB issued an updated 2025 Small Business Lending Filing Instructions Guide (the “Guide”), which includes the new compliance dates for submitting required data.
It should be noted that the District Court, on August 26, rejected the trade group’s arguments attacking the CFPB’s small business data regulation. It will likely be appealed to the Fifth Circuit where the outcome is uncertain.
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