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Lenders urge CFPB to scale back small-business data collection plan – American Banker

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It’s been called a fishing expedition. A burden on small banks and credit unions. An example of regulatory overreach.
A proposal to collect data on the race, ethnicity and gender of small-business borrowers has drawn nearly 1,700 comments to the Consumer Financial Protection Bureau, with many of them expanding on the criticism that had been building since it was unveiled in September.
Many community bankers and credit union executives said the rule would make it harder for small financial institutions to compete, forcing some to exit small-business lending entirely. Others said aspects of the data collection were at odds with how many banks do business.
Bankers are worried that the CFPB will use the small-business data to find targets for fair-lending investigations given that Director Rohit Chopra has put the fight against redlining at the top of his agenda.
“When implemented thoughtfully and in partnership with key stakeholders, collecting more data on small-business lending has great potential to advance our shared goals of financing the American Dream for minority- and woman-owned businesses and expanding access to credit in underserved communities,” wrote David Pommerehn, general counsel and senior vice president at the Consumer Bankers Association. “However, there is also an increased risk of collecting misleading or incomplete data that could negatively impact small businesses and stifle small-business lending.”

In comment letter after comment letter, bankers urged the CFPB to throttle back its proposal, essentially trying to chip away at the number of institutions that would be required to report.
Trade groups seek outright exemptions for smaller institutions. The Credit Union National Association is asking for entities with $600 million of assets or less to be exempt. The Independent Community Bankers of America wants banks with assets of $1.3 billion of assets or less to be excluded.
“Community bank small-business lending is complex — it should not be commoditized and subjected to simplified, rigid analysis that would have a chilling effect on small-business lending,” wrote ICBA President and CEO Rebeca Romero Rainey. “While ICBA supports the proposal’s goal of expanding access to credit for minority-owned, women-owned and small businesses, we are concerned that its overly broad coverage will disadvantage community bank business customers.”
Many commenters expressed concern that small banks and credit unions lack the resources to hire more employees to collect and submit the data.
“The CFPB’s small-business lending data collection rulemaking will likely add substantial strain on credit unions’ finite resources,” wrote Andrew Oliphant, a retail training mentor at Meritrust Credit Union in Wichita, Kansas. “This strain, coupled with the regulatory challenges already facing credit unions in the business-lending space, could lead credit unions to reduce their loan offerings to small businesses, eliminate those offerings altogether or discourage credit unions from offering business loans in the future.”
The CFPB’s proposal was released last year and has been a decade in the making, required by Section 1071 of the Dodd-Frank Act. The lack of a comprehensive database on small-business lending has been a major barrier to government relief efforts during the coronavirus pandemic. Some analysts have faulted the lack of small-business data as an issue in the rollout and tracking of the Small Business Administration’s Paycheck Protection Program.
“It is not possible with current data to confidently answer basic questions regarding the state of small-business lending,” the CFPB said in issuing its proposal.
Financial institutions that originate at least 25 small-business loans a year for two consecutive years would have to collect and report the data. Some bankers asked that the threshold be raised to 500 or 1,000 loans a year.
A minimum of 13 specific data points would be collected. Dodd-Frank gave the CFPB the authority to expand the data even further. Consumer groups want more data added. For example, the National Community Reinvestment Coalition urged the bureau to collect the annual percentage rate on small-business loans and credit scores from small-business loan applicants.
Bankers want less data collected. Some bankers asked the CFPB to redefine a small business as an entity with no more than $1 million a year in revenue, a fraction of the proposal’s current definition of $5 million in revenue.
Ann-Marie Weasel, a banker at the $1.1 billion-asset Union Bank Co. in Columbus Grove, Ohio, urged the CFPB to create even more exemptions, give lenders three years to get ready to comply with the final rule, and make other changes.
“In the end, the data collection may reduce the availability of credit and increase its cost,” Weasel wrote.
Still, the majority of letters did not directly address the elephant in the room: collecting data on small-business loans is expected to lead to more fair-lending enforcement and potentially the public shaming of banks for alleged discrimination against minority-owned businesses. Instead, bankers hewed to the theme that the proposal would add to their already onerous compliance costs.
A point of contention also came from the CFPB’s proposal that lenders themselves identify the race, ethnicity and gender of the principal owners of a small business based on a person’s surname or visual clues. Bankers say that requirement puts them in a bad position.
“The financial institution should not be required to verify or use any other information or best guess based on visual observation, surname or any other basis,” wrote Kenneth A. Witbrodt, CEO of the $1.2 billion-asset Montgomery Bank in Sikeston, Missouri. “The financial institution should report the data provided, or not provided, by the applicant. If the applicant chooses not to supply information, that wish should be honored.”
Many bankers also said the CFPB’s proposal would put small banks at a competitive disadvantage. A requirement that lenders create a “firewall” to prevent employees involved in lending decisions from knowing the race, ethnicity and sex of an applicant was widely seen as unworkable.
“For most banks, the commercial loan officer collects the application information from the applicant and deals directly with the applicant throughout the lending process. As a result, the lender is already clearly aware of this information,” said Paul Reherman, a senior vice president at the $3.7 billion-asset Interbank in Oklahoma City, Oklahoma. “Implementing a firewall process to separately collect this information will create an additional burden on financial institutions and really does not accomplish the intent of the firewall. We request that this requirement be removed.”
Bankers also expressed concerns about the data being made available to the public. The CFPB has said it plans to modify or delete information to protect borrowers’ privacy. The bureau also is proposing a “balancing test” that would assess the risks and benefits of public disclosure. The test would be conducted after the first year the data is received.

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TOP 4 Essay Writing Services in the USA: 2023 Edition

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essay writing services reddit

As an increasing number of students seek assistance with their academic assignments, the demand for reliable essay writing services continues to grow. With so many options available, it can be challenging to identify the best service providers. To help you make an informed decision, we have compiled a list of the top 4 essay writing services in the USA for 2023. These services have been carefully evaluated based on their reputation, quality of work, customer satisfaction, and affordability. Read on to discover the top essay writing services that can provide you with the support you need to excel in your academic journey.

essay writing services reddit

essay writing services reddit

What Makes a Great Essay Writing Service

Before delving into the top essay writing services reddit, it’s essential to understand the criteria we used to evaluate them. A great essay-writing service should possess the following qualities:

  • Quality of Work: The service should deliver well-researched, original, and high-quality essays that meet academic standards.
  • Professional Writers: The service should have a team of qualified writers with expertise in various subjects who can handle diverse topics.
  • Timely Delivery: The service should be reliable and capable of delivering essays within the given deadline.
  • Customer Support: The service should provide excellent customer support, ensuring effective communication throughout the writing process.
  • Affordability: The service should offer reasonable pricing plans that are affordable for students while maintaining the quality of work.

Now, let’s explore the top 4 essay writing services in the USA for 2023.

TOP 4 Essay Writing Services in the USA: 2023 Edition

2.1 EssayPro

EssayPro is a highly reputable essay writing service known for its commitment to quality and customer satisfaction. They have a diverse team of experienced writers who can handle a wide range of subjects. EssayPro offers a user-friendly platform, allowing students to place orders easily and track the progress of their essays. Their pricing is competitive, and they offer additional features such as plagiarism reports and unlimited revisions.

2.2 Grademiners

Grademiners is a popular choice among students due to its excellent track record and reliability. They have a team of highly skilled writers who are proficient in various academic disciplines. Grademiners ensures on-time delivery and provides 24/7 customer support to address any concerns. They also offer free revisions and a money-back guarantee, ensuring customer satisfaction.

2.3 Ultius

Ultius is known for its exceptional writing services and commitment to customer privacy and security. They have a rigorous writer selection process, ensuring that only qualified professionals handle the essays. Ultius offers a wide range of writing services, including essay writing, editing, and proofreading. They also provide a mobile app for convenient communication and order tracking.

2.4 EduBirdie

EduBirdie is a trusted essay writing service that offers a unique feature called “choose your own writer.” Students can browse through profiles and select a writer who matches their requirements. This personalized approach allows for effective collaboration and ensures that the final essay meets the student’s expectations. EduBirdie also provides 24/7 customer support and guarantees 100% original and plagiarism-free content.

How We Evaluated the Services

To evaluate the essay writing services, we considered several factors, including:

  • Reputation and reliability
  • Quality of work and adherence to academic standards
  • Customer reviews and satisfaction
  • Pricing and affordability
  • Additional features and guarantees
  • Customer support and communication

By carefully analyzing these aspects, we identified the top 4 essay writing services that offer outstanding support to students.

Conclusion

Choosing a reliable essay writing service is crucial for students seeking academic assistance. The top 4 essay writing services mentioned in this article – EssayPro, Grademiners, Ultius, and EduBirdie – have proven their worth in terms of quality, reliability, and customer satisfaction. Whether you need help with an essay, research paper, or any other academic assignment, these services can provide you with the support you need to succeed in your studies.

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