Small Business Lending Data Collection Under the Equal Credit Opportunity Act (Regulation B)
The CFPB proposes to require small business lenders, including auto dealers that originate loans, to collect and report data on credit applications, including demographic information about business owners, to enforce fair lending laws.
Aforeworn detected this change in the Auto Dealer F&I Compliance space on July 6, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. Franchise dealers, independent used-car dealers, BHPH dealers, and F&I managers who originate small business loans (including commercial vehicle loans or dealer floor plans). should confirm how it applies to their specific situation before acting. There is a time constraint attached: Public comment period ends December 13, 2021; final rule expected later. Compliance likely required within 12-18 months after final rule.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Auto Dealer F&I Compliance continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
Proposed rule would expand data collection requirements under Regulation B to include small business lending data, potentially covering dealer-arranged financing for business-purpose vehicles.
Who it affects
Franchise dealers, independent used-car dealers, BHPH dealers, and F&I managers who originate small business loans (including commercial vehicle loans or dealer floor plans).
What you must do
Review current lending practices to determine if your dealership originates small business loans; prepare to implement systems to collect and report applicant demographic data (e.g., race, sex, ethnicity) for covered loans.
Deadline
Public comment period ends December 13, 2021; final rule expected later. Compliance likely required within 12-18 months after final rule.
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