1. Introduction

Dear CRC Economic Development Committee and allies

Thank you for agreeing to take part in this survey and for helping to shape our comments to the Consumer Financial Protection Bureau (CFPB) on small business lending needs.

For 20 years, CRC members and allies have been advocating for public data that would show which lenders are making what types of small business loans to which business owners, and where. Such data have existed for home mortgage lending for years and that data transparency has led to better and more fair lending by mortgage lenders - or to enforcement of fair housing laws when it did not. In the Dodd Frank Act, Congress charged the CFPB with developing this small business lending data set in §1071. The purpose of these data are to help identify small business lending needs, help local governments to allocate resources, and to help identify possible discrimination.

The CFPB publicly began the process of developing the 1071 data rule in a Request for Information (RFI) released on May 10 at the field hearing in Los Angeles attended by many of you. We think this is a very important opportunity to improve data transparency and ultimately, to increase access to credit for small businesses across the state and nation.

We will use the results of this survey to develop a sign-on comment letter, which is due next month. We will come back to you before then for your support on that. We will also do media outreach in order to get our message out and to support the CFPB throughout this process.

Please respond to the survey by July 21, 2017. And please let us know if you have any questions. Thanks so much for your support of our advocacy, and for your work to increase access for small businesses.

 
Robert Villarreal, Chair, CRC Economic Development Committee             

Kevin Stein, CRC

Note: We welcome participation in the survey from as many as possible, including more than one staff at the same organization

* 1. How important is the CFPB 1071 small business data collection effort to small business owners and their ability to access credit?

* 2. Where do small business owners turn for financing?

  OFTEN APPLY for this financing OFTEN RECEIVE this financing SOMETIMES APPLY for this financing SOMETIMES RECEIVE this financing NEVER APPLY for this financing NEVER RECEIVE this financing
Big Banks
Smaller Regional or Local Banks
Credit Card Lenders 
Credit Unions  
CDFIs or Other Community Lenders  
Nonbanks (Online, Marketplace, Fintech Lenders)  
Brokers/Finders   Not sure
Families and/or Friends
Merchant Cash Advance Providers
Factoring
Leasing

* 3. How should the CFPB define "small business" for the purpose of small business data collection rules?

* 4. In your experience with BANKS and small businesses, how common are the following?

  Very Common Somewhat Common Not Common
Small businesses are able to get term loans and lines of credit
Term loans and lines of credit actually help meet the credit needs of small businesses
Small businesses seek term loans and lines of credit from banks, but are offered credit card loans instead
Small businesses seek and receive credit card loans
Credit card loans from banks actually help meet the credit needs of small businesses
Small banks are more responsive than large banks to small business credit needs. If so, please explain below

* 5. In your experience with NON BANKS and small businesses, how common are the following?

  Very Common Somewhat Common Not Common
Small businesses get non bank, fintech loans
Non bank, fintech loans are beneficial to the small businesses who receive them
Small businesses get Merchant Cash Advance (MCA) or similar products that commit a % of future credit card or other receivables/revenue to repayment?
These MCA or similar products are beneficial to the small businesses who receive them

* 6. The state Department of Business Oversight (DBO) reports a huge increase in online lending in the state. In California, the aggregate dollar amount of such lending increased by 786.3 percent, to $452.2 million in 2014. The total through the first half of 2015 was $350.7 million.

Do you think MORE, LESS, or the CURRENT level of regulation and enforcement is appropriate to deal with non bank and fintech lending, such as Merchant Cash Advance, in order to protect small businesses?

* 7. Do you think small business owners face discrimination based on race, sex, age, national origin, or marital status, or because one receives public assistance?

* 8. Do you see or work with small business owners that have faced, or are facing, displacement (increasing rents, competition from newer and bigger businesses, changing character of neighborhood residents, etc), as gentrification pressures come to their neighborhoods?

* 9. The CFPB currently has a consumer complaint database that has received over 1 million complaints from consumers, though very few complaints have been filed by small businesses. The CFPB's primary small business authority relates to developing the 1071 lending data rule, and to enforcing the Equal Credit Opportunity Act. Should the CFPB, or another agency, encourage and make it easier for small businesses to file complaints relating to possible discrimination or problems accessing credit?

* 10. What types of data and information are currently collected by small business lenders, by type of lender and how data are reported (check all that apply)?

  Revenue of business Number of business employees Type of business or industry Location of business Race/ethnicity/gender of business owners Size of loan Type of loan (term, line, credit card, % of receivables, etc) Cash flow of businesses Tax returns Collateral or guarantee for loan
Traditional Financial Institutions (banks, credit unions)
Non Bank Financial Institutions (fintech, marketplace, Merchant Cash Advance, etc)
Data are self reported by small business owner
Data are verified by the lender

* 11. What challenges do small business face in accessing credit? What obstacles do minority and women owned businesses in particular face?

* 12. In your view, what would be the most impactful way to help small businesses grow? What should CRC do to advance a small business agenda?

* 13. Please provide one story of a small business owner that is representative of the experience of small business owners in trying to access credit today (please indicate if it is or is not OK to share this story)

* 14. Please provide your contact information

* 15. Are you interested in participating in media and other advocacy to support CFPB 1071 small business data collection specifically, and a small business agenda more broadly?

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