After more than ten years and extended litigation to compel rulemaking, on March 30, 2023, the Consumer Financial Protection Bureau (CFPB) issued the final rule which implements the small business lending data collection requirements set forth in section 1071 of the Dodd-Frank Act (Section 1071).  The final rule, together with the comments, is just under nine hundred pages.[1]  Broadly presented, the final rule can be broken down into a series of questions to be answered.  First, are the lender, the borrower and the transaction covered by the rule?  Second, what information must be collected and reported?  Third, how is the information reported?  Fourth, when does the rule take effect?

After historic GDP growth and retail sales in 2021, are the days of unprecedented growth over for your retail clients? The short answer: It’s complicated.

If the last two years have shown us anything, it is that uncertainty is the new normal. When COVID shut down the economy in March 2020, the impact on the retail sector was profound. In some parts of the country, brick and mortar stores were closed for up to 90 days and in-person sales ground to a halt for all but the most essential items.