In an unprecedented joint action, bankers associations from every U.S. state penned a shared letter to the Consumer Financial Protection Bureau (CFPB or Bureau) on August 8, voicing their collective request for a delay in the enforcement and implementation of the small business data collection and reporting final rule stipulated under § 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Final Rule). The appeals are directed specifically to financial institutions covered by the Final Rule.
The rationale behind their joint request for a delay is related to a pending U.S. Supreme Court case, namely Community Financial Services Association (CFSA) v. CFPB. The bankers associations have urged the CFPB to delay the fresh legal obligations to financial institutions until the Supreme Court delivers its final decision in the CFSA v. CFPB case.
This deeply significant development in the banking and legal sectors has been outlined in greater detail in a piece on JD Supra, authored by the law firm Troutman Pepper.