Tuesday, July 12, 2016

FDIC Launches Survey Regarding Small Business Lending Practices


The FDIC has launched a web based survey of roughly 2,000 randomly selected FDIC-insured banks regarding their small business lending practices.  This comes on the heals of the CFPB revelation that small business lending is also on their rulemaking agenda.  In May, the CFPB announced that it was in the very early stages of implementing Section 1071 of the Dodd Frank Act which amends the Equal Credit Opportunity Act to require financial institutions to report information concerning credit applications made by women owned, minority owned and small businesses. 

At the end of June, the FDIC issued a press release announcing their survey.  As its  rationale, the FDIC states that “[s]mall business lending is an important way that banks help meet their communities' needs, especially for the many banks that primarily focus on commercial rather than consumer lending…Despite the importance of small businesses to the U.S. economy and the importance of bank lending to small businesses, there is little high quality data on small business lending by banks. The FDIC Small Business Lending Survey (SBLS) is designed to help fill in this information gap.”  The survey also includes questions concerning consumer transactions which are responsive to a Congressional mandate to learn more about bank efforts to bring unbanked individuals into the conventional finance system. Responses to the survey are due August 10th.

The purpose of the survey is the provide insight into many aspects of small business lending, including nationally representative information on the general characteristics of small business borrowers, the types of credit sought and offered, and the relative importance of small business lending to banks of different sizes, business models and location.  The survey is broken down into six sections; (a) questions concerning the 2015 small business borrowers at the surveyed institution; (b) questions concerning the 2015 total loan originations of the surveyed institution; (c) questions concerning commercial and industrial loan originations of the institution in 2015; (d) questions concerning outstanding commercial and industrial  loans reported on the institutions call report in 2015; (e) questions concerning the small business “commercial and industrial lending competition, practices and applications” for the surveyed institution; and (f) consumer account offerings and policies.



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