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Empire Justice Comments to CFPB Concerning Small Business Lenders in Rochester, NY

September 7, 2017


Ms. Monica Jackson
Office of the Executive Secretary
Consumer Financial Protection Bureau
1700 G St. NW
Washington, DC 20552

RE: Request for Information Regarding the Small Business Market, Docket No. CFPB-2017-0011
Dear Ms. Jackson:

Empire Justice Center is submitting these comments to share information with the CFPB  about our experience with CRA small business lenders in the Rochester, NY MSA.

We regularly use the CRA small business lending data to analyze banks’ CRA performance or when commenting on mergers. While we find that the public CRA lending data adds to our understanding of the CRA performance by banks in their communities, compared to the publicly available HMDA data, the current formulation of the data has severe limitations.

The small business sector is critical to the nation’s job creation, economic growth and continued recovery, yet lawmakers, regulators and the communities lack basic information about the credit needs of small businesses and their ability to obtain credit.   Several studies have documented the challenges small businesses, particularly those that are women-owned and minority-owned, face in accessing credit, including receiving lower dollar amounts for loans, higher denial rates, and having to pay higher rates and fees. The final rule must be a strong rule that captures most of the lending in the market, information about products and pricing, as well as information on loan applications and denials.  This is necessary to understand and address the disparities in lending and to promote economic growth throughout the country.

CLICK HERE to read our comments.

For more information, please contact:

Ruhi Maker

Empire Justice Center
Telesca Center for Justice
One West Main Street, Suite 200
Rochester, NY  14614 

(585) 454-4060
(585) 454-2518