Small Business Lending Data Collection Extension

|2024-14396|228 days overdue
View on Federal Register

Summary

In light of court orders in ongoing litigation, the Consumer Financial Protection Bureau (CFPB or Bureau) is amending Regulation B to extend the compliance dates set forth in its 2023 small business lending rule and to make other date-related conforming adjustments.

Compliance Requirements

  1. #1

    Covered financial institutions must begin collecting data as follows: Highest volume lenders by July 18, 2025; Moderate volume lenders by January 16, 2026; Smallest volume lenders by October 18, 2026; Covered financial institutions must submit their small business lending application registers to the CFPB on or before June 1 following the calendar year for which the data are compiled and maintained; Financial institutions are permitted to collect protected demographic information required under the 2023 final rule from small business applicants beginning 12 months prior to its compliance date; Financial institutions may use their originations of covered credit transactions in each of calendar years 2023 and 2024, rather than those in 2022 and 2023, to determine its compliance date; A financial institution that is unable to determine the number of covered credit transactions it originated in 2022 and 2023 for purposes of determining its compliance tier is permitted to use any reasonable method to estimate its originations to small businesses for either or both of 2022 and 2023; Financial institutions are permitted to use any reasonable method to estimate their originations for either or both of 2023 and 2024; Comments must be received on or before [INSERT DATE 30 DAYS AFTER PUBLICATION IN THE FEDERAL REGISTER]

    Deadline: 2025-07-18(July 18, 2025 for Tier 1, January 16, 2026 for Tier 2, October 18, 2026 for Tier 3)

Market Impacts

  • Delayed implementation of small business lending data collection requirements under Regulation B, extending compliance deadlines by 290 days from original dates; Extended period for voluntary early collection of protected demographic data allows financial institutions to test procedures and systems before mandatory compliance; Delayed implementation of fair lending data collection may temporarily reduce transparency in small business lending markets, potentially affecting market efficiency; Mandatory extension of compliance dates affects approximately 100 Tier 1 institutions, 450 Tier 2 institutions, and 2,000 Tier 3 institutions nationwide

Validated Company Impacts

FBPScore: 100%

FIRST BANCORP /PR/

First Bancorp operates as a financial institution offering commercial and industrial loans, which directly aligns with the rule's focus on covered credit transactions for small businesses. The company's lending activities in both Puerto Rico and Florida regions fall under Regulation B's jurisdiction, requiring compliance with small business lending data collection requirements. The rule focuses on small business lending compliance requirements and data collection timelines for financial institutions, while the company's only identified risk is cybersecurity threats related to technology operations. There is no overlap between the regulatory compliance requirements of this lending rule and the company's cybersecurity risk profile.

ALLYScore: 100%

Ally Financial Inc.

Ally Financial operates as a digital financial services company, directly placing it within the scope of financial institutions covered by Regulation B's small business lending requirements. The company's core business model involves credit transactions and lending activities, making it highly likely to be subject to the data collection and compliance obligations outlined in this rule. The rule focuses specifically on small business lending data collection requirements under Regulation B, which does not align with any of the company's disclosed risk factors. The company's regulatory risks center on capital framework implementation and long-term debt requirements, not fair lending compliance or small business credit data reporting.

ASBScore: 100%

ASSOCIATED BANC-CORP

Associated Banc-Corp operates as a financial institution with significant small business lending activities through both its Corporate and Commercial Specialty and Community, Consumer and Business segments, directly falling under Regulation B's coverage for financial institutions with covered credit transactions for small businesses. The company's lending solutions and deposit services align precisely with the rule's requirements for data collection and reporting on small business lending applications. The rule focuses specifically on small business lending data collection compliance under Regulation B, which does not directly align with any of the company's identified risk factors. The company's regulatory compliance risk is general capital requirements, not fair lending data reporting, and its operational credit loss risk relates to loan performance rather than application data collection.

AUBScore: 100%

Atlantic Union Bankshares Corp

Atlantic Union Bankshares Corp operates as a regional bank holding company providing commercial and consumer banking services, including small business lending, which directly falls under Regulation B's requirements for covered financial institutions collecting small business lending data. The company's core business of originating credit transactions to small businesses aligns perfectly with the rule's scope and compliance obligations. The rule focuses on small business lending data collection compliance requirements, which does not align with any of the company's identified risk factors. The company's single regulatory risk relates to merger approval delays, not lending compliance, and its other risks are financial, operational, and competitive in nature with no connection to small business lending regulations.

AXScore: 100%

Axos Financial, Inc.

Axos Financial operates a significant banking business segment that distributes loan products through multiple channels, directly aligning with Regulation B's requirements for financial institutions collecting small business lending data. As a technology-driven financial services company offering banking solutions to business customers, it would be classified as a covered financial institution required to comply with small business lending data collection and reporting obligations. The company's single regulatory compliance risk (non-GAAP financial measures) shows minimal alignment with this rule's focus on fair lending data collection and small business credit reporting. The company's primary risks center on financial accounting and valuation issues rather than consumer protection or lending compliance requirements.

BACScore: 100%

BANK OF AMERICA CORP /DE/

Bank of America is a major financial institution that engages in small business lending as part of its core banking operations, directly falling under Regulation B's requirements for covered financial institutions. The company's extensive lending activities to small businesses clearly place it within the scope of this rule's data collection and compliance obligations. The company's disclosed risk factors focus primarily on financial reporting, asset valuation, and accounting compliance, with no mention of lending operations, credit risk, or fair lending compliance. The rule specifically targets small business lending data collection and fair lending practices, which do not align with the company's identified risk areas.

BANFScore: 100%

BANCFIRST CORP /OK/

BancFirst Corporation operates as a commercial banking institution that provides lending services to businesses, directly falling under the rule's scope as a financial institution with covered credit transactions for small businesses. The company's core business model involves commercial banking services, including small business lending, which aligns perfectly with Regulation B's requirements for data collection and reporting on small business lending activities. The rule focuses on small business lending data collection compliance under ECOA Regulation B, which does not align with any of the company's disclosed risk factors. The company's regulatory risks center on Patriot Act compliance, OFAC sanctions, and interchange fees, none of which relate to fair lending data reporting requirements for small business credit.

CFGScore: 100%

CITIZENS FINANCIAL GROUP INC/RI

Citizens Financial Group operates as a financial institution that makes loans to small businesses, directly falling under the rule's jurisdiction as a covered financial institution with small business lending activities. The company's core business model of deposit taking and loan making aligns perfectly with Regulation B's requirements for collecting and reporting small business lending data. The company has identified regulatory compliance risks as a top concern, which aligns with this rule's focus on new compliance requirements for financial institutions. However, the company's specific regulatory risk mentions restrictions on activities and increased costs affecting business expansion, while this rule primarily involves data collection and reporting deadlines rather than direct activity restrictions.

COLBScore: 100%

COLUMBIA BANKING SYSTEM, INC.

Columbia Banking System operates as a financial institution that provides small business lending services, directly falling under the rule's jurisdiction as a covered financial institution required to collect and report small business lending data under Regulation B. The company's core business activities involve originating credit transactions for small businesses, making it clearly subject to the compliance requirements and deadlines specified in this rule. The rule focuses on small business lending data collection compliance requirements, which does not align with any of the company's identified risk factors. The company's single regulatory compliance risk is generic and not specifically tied to lending data reporting or fair lending requirements under Regulation B.

CVBFScore: 100%

CVB FINANCIAL CORP

CVB Financial Corp operates Citizens Business Bank, which provides banking services including lending to small businesses, directly falling under the rule's scope as a financial institution with covered credit transactions. The company's core business model involves lending activities that would require compliance with Regulation B's small business lending data collection requirements. The rule directly addresses regulatory compliance risks in small business lending, which aligns with the company's identified regulatory compliance risks (6 risks) and credit risks (4 risks). The extended compliance deadlines and data collection requirements specifically impact financial institutions' lending operations and fair lending compliance, matching the company's exposure to regulatory and credit-related vulnerabilities.

EBCScore: 100%

Eastern Bankshares, Inc.

Eastern Bankshares operates as a regional banking institution that provides banking and financial services, directly aligning with the rule's focus on financial institutions engaged in lending activities. The company's core business of providing credit and financial solutions to customers places it squarely within the scope of Regulation B's small business lending data collection requirements. The rule focuses specifically on small business lending data collection compliance requirements, which does not directly align with any of the company's identified risk factors. While the company has one regulatory compliance risk identified, it is not specified as relating to lending or data collection, resulting in minimal relevance.

EFSCScore: 100%

ENTERPRISE FINANCIAL SERVICES CORP

Enterprise Financial Services Corp operates as a financial institution offering extensive commercial lending services including commercial and industrial loans, which directly fall under the rule's coverage of small business lending. The company's core business model involves originating credit transactions to businesses, making it clearly subject to Regulation B's data collection and compliance requirements for covered financial institutions. The rule's focus on small business lending data collection and fair lending compliance has weak alignment with the company's risk profile, which emphasizes credit loss, real estate market, and construction loan risks rather than regulatory data reporting. While the company identifies compliance risk as a category, the specific requirements of this rule (demographic data collection, application register reporting) do not directly address the types of compliance risks highlighted in their profile.

FBKScore: 100%

FB Financial Corp

FB Financial Corp operates through FirstBank, a banking institution that provides lending services, directly aligning with the rule's focus on financial institutions with covered credit transactions for small businesses. As a bank, it would be required to comply with Regulation B's small business lending data collection and reporting requirements. The rule focuses on small business lending data collection compliance deadlines, which does not align with the company's primary risk factors of dividend restrictions and capital requirements. The company's regulatory compliance risks are centered on capital adequacy and dividend approvals, not fair lending data reporting obligations.

FLGScore: 100%

FLAGSTAR FINANCIAL, INC.

Flagstar Financial operates as a financial institution providing small business lending through its commercial and industrial loan segment, directly falling under Regulation B's requirements for covered financial institutions collecting small business lending data. The company's core banking operations involve credit transactions that would require compliance with the extended data collection deadlines. The rule directly impacts the company's identified Legal and Regulatory Risk by imposing new compliance requirements for small business lending data collection, which could increase compliance costs. It also affects Operational Risk through the need for system changes to collect and report demographic data, potentially causing financial loss if processes fail.

IBOCScore: 100%

INTERNATIONAL BANCSHARES CORP

International Bancshares Corp operates as a bank holding company with subsidiary banks providing commercial and retail banking services, directly engaging in small business lending activities that fall under Regulation B's requirements. The company's core business of originating credit transactions to small businesses in Texas and Oklahoma clearly places it within the scope of covered financial institutions subject to these compliance deadlines and data collection mandates. The rule's focus on small business lending data collection and compliance deadlines has minimal alignment with the company's disclosed risk factors. While the company identifies regulatory constraints as a risk, this specific rule addresses data reporting requirements rather than the dividend payment limitations mentioned in their risk profile. The company's primary risks center on loan loss allowances, competition, and liquidity - none of which are directly impacted by this Regulation B extension.

MTBScore: 100%

M&T BANK CORP

M&T Bank Corp operates as a commercial bank that provides lending services to small businesses, directly falling under the scope of Regulation B's small business lending data collection requirements. As a financial institution with commercial banking operations, it would be required to comply with the extended compliance dates for collecting and reporting small business lending application data. The rule's focus on regulatory compliance requirements for small business lending data collection has weak alignment with the company's single identified regulatory compliance risk. While the company acknowledges legislative and regulatory changes as a risk, there is no specific mention of fair lending, small business lending, or data collection compliance in their risk profile.

NTRSScore: 100%

NORTHERN TRUST CORP

Northern Trust Corp operates as a major financial institution providing lending services, including commercial banking and credit products that would include small business lending. As a covered financial institution under Regulation B, it would be required to comply with the small business lending data collection requirements and extended compliance deadlines specified in this rule. The rule specifically targets financial institutions engaged in small business lending and compliance with Regulation B data collection requirements. The company's risk factors focus on technology, cybersecurity, and general business operations with no mention of lending activities, financial regulation compliance, or fair lending practices, showing no alignment with this rule's risk impacts.

PNFPScore: 100%

PINNACLE FINANCIAL PARTNERS INC

Pinnacle Financial Partners is a regional bank that provides commercial lending services to small businesses, directly falling under Regulation B's requirements for covered financial institutions with small business credit transactions. The company's core business operations involve originating loans to small businesses, making it subject to the data collection and reporting mandates outlined in this rule. The rule primarily addresses regulatory compliance requirements for small business lending data collection, while the company's disclosed risks focus on financial performance, operational costs, and market competition with minimal regulatory compliance concerns. Only the FDIC assessments risk shows any tangential connection to regulatory costs, but this rule specifically targets lending data reporting rather than deposit insurance assessments.

RFScore: 100%

REGIONS FINANCIAL CORP

Regions Financial Corp operates as a covered financial institution that engages in small business lending through its Corporate Bank segment ($102.3B in commercial lending) and provides credit transactions that fall directly under Regulation B's requirements. The company's core banking operations and lending activities align perfectly with the rule's scope for data collection and compliance reporting on small business credit applications. The rule directly addresses legal and regulatory compliance risks, which the company has explicitly identified as a top concern. The extended compliance deadlines and data collection requirements align with the company's litigation and investigations risk, as non-compliance could result in regulatory penalties and reputational harm.

RNSTScore: 100%

RENASANT CORP

Renasant Corp operates as a financial institution providing small business lending services, directly falling under Regulation B's scope for covered financial institutions with small business credit transactions. The company's core banking operations involve originating loans to small businesses, making it subject to the rule's data collection and compliance requirements. The rule focuses on small business lending data collection and compliance deadlines, while the company's risk factors primarily address credit quality, loan performance, and economic impacts on lending. There is minimal overlap as the company's single regulatory compliance risk relates to credit loss allowance methodology, not small business lending data reporting requirements.

SOFIScore: 100%

SoFi Technologies, Inc.

SoFi Technologies operates as a financial services company that originates loans, including small business lending, which directly falls under Regulation B's requirements for covered financial institutions. The company's loan origination business model and financial services operations align strongly with the rule's scope for collecting small business lending data and demographic information. The rule focuses on small business lending data collection and compliance deadlines under ECOA Regulation B, which does not align with the company's disclosed risk factors of deferred tax assets valuation, impairment charges, and accounting standards compliance. The company's regulatory compliance risk relates to financial reporting standards rather than consumer lending regulations.

SSBScore: 100%

SouthState Corp

SouthState Corp operates as a regional bank providing financial services, which directly aligns with the rule's focus on financial institutions engaged in small business lending. As a banking institution, it would be subject to Regulation B's requirements for collecting and reporting small business lending data, making this rule highly relevant to its core operations. The company's single regulatory compliance risk relates to approval for a sale-leaseback transaction, which does not align with the small business lending data collection requirements of this rule. The rule focuses on fair lending compliance and data reporting for financial institutions engaged in small business credit, whereas the company's disclosed risks center on acquisition integration, market expansion, and property operations with no mention of lending activities or fair lending concerns.

SYBTScore: 100%

Stock Yards Bancorp, Inc.

Stock Yards Bancorp operates as a commercial bank providing lending services to businesses, which directly aligns with Regulation B's requirements for financial institutions collecting small business lending data. The company's commercial banking segment originates covered credit transactions to small businesses, making it subject to the rule's compliance deadlines and data collection obligations. The rule focuses on small business lending data collection compliance, which does not align with the company's primary risk factors of deposit pricing pressure, credit loss volatility, and interest rate risk. The company has minimal regulatory compliance risks identified (only 4 out of 62 total risks), and none specifically mention lending compliance or ECOA/Regulation B requirements.

TCBIScore: 100%

TEXAS CAPITAL BANCSHARES INC/TX

Texas Capital Bancshares operates as a financial institution with significant small business lending activities through its commercial banking segment, including lines of credit, term loans, and equipment financing for businesses. The company's core banking operations directly align with Regulation B's requirements for covered financial institutions to collect and report small business lending data, making it clearly subject to these compliance obligations. The company has only one regulatory compliance risk identified, but it is generic and not specifically tied to lending or fair credit practices. The rule's focus on small business lending data collection and fair lending compliance does not align with the company's disclosed financial and operational risks, which center on credit losses, debt management, and capital position rather than regulatory reporting requirements.

TRMKScore: 100%

TRUSTMARK CORP

Trustmark Corporation operates as a bank holding company providing traditional banking services including loans, which directly falls under the scope of Regulation B's small business lending requirements. As a financial institution offering credit transactions, it would be required to comply with the data collection and reporting mandates for small business lending applications. The rule focuses on small business lending data collection and fair lending compliance, while the company's risk profile is dominated by interest rate risk, derivatives market exposure, and asset/liability management concerns. There is minimal overlap as the company's single regulatory compliance risk relates to derivatives regulation, not consumer lending or ECOA requirements.

UPSTScore: 100%

Upstart Holdings, Inc.

Upstart operates as a financial technology company that provides AI-powered lending platforms, including small business lending solutions, directly falling under Regulation B's scope for covered financial institutions with small business credit transactions. The company's core business of originating and facilitating small business loans through its platform aligns precisely with the rule's requirements for data collection and reporting on small business lending applications. The company's risk factors show no alignment with this small business lending regulation. The rule specifically targets financial institutions engaged in small business credit transactions, while the company operates in the technology sector with risks focused on cybersecurity, intellectual property, and market competition rather than lending compliance or fair credit practices.

WSBCScore: 100%

WESBANCO INC

Wesbanco is a financial institution that manages liquidity risk and maintains a stable core deposit base, directly aligning with the rule's focus on covered financial institutions involved in lending activities. The company's operations in small business lending would require compliance with Regulation B's data collection and reporting requirements for covered credit transactions. The company has 7 identified regulatory compliance risks, which directly aligns with this rule's requirement for financial institutions to implement new data collection and reporting systems. The rule's compliance cost impacts and operational changes match the company's regulatory action risk factor, and the extended timeline provides some mitigation for integration challenges.

WSFSScore: 100%

WSFS FINANCIAL CORP

WSFS Financial Corp operates as a financial institution that provides small business lending services, directly falling under the scope of Regulation B's requirements for covered financial institutions to collect and report small business lending data. The company's core business activities in commercial lending and banking services align perfectly with the rule's jurisdiction over financial institutions with covered credit transactions for small businesses. The rule focuses on small business lending data collection compliance requirements, while the company's risk factors primarily address credit loss provisioning, operational costs, and commercial real estate market risks with no mention of lending compliance, fair lending, or data collection obligations. The only tangential connection is the regulatory compliance risk category, but the specific nature doesn't align with small business lending data reporting requirements.

AXPScore: 100%

AMERICAN EXPRESS CO

American Express operates a Commercial Services segment that specifically targets small businesses with credit products, making it a covered financial institution under Regulation B's small business lending requirements. The company's card-issuing business model involves extending credit to small businesses, directly aligning with the rule's data collection and compliance obligations for covered credit transactions. The rule focuses specifically on small business lending data collection requirements under Regulation B, which does not align with the company's disclosed risk factors. The company's regulatory compliance risks (11 identified) are generic and not specific to consumer financial protection or small business lending regulations, while its operational risks center on technology and cybersecurity rather than fair lending compliance.

BANCScore: 100%

BANC OF CALIFORNIA, INC.

Banc of California operates as a bank holding company providing banking products and services, directly falling under the scope of financial institutions covered by Regulation B's small business lending requirements. The company's core business of lending and credit transactions aligns perfectly with the rule's focus on collecting small business lending data and demographic information. The rule focuses on small business lending data collection compliance requirements, which does not align with any of the company's disclosed risk factors. The company's risks center on merger integration, interest rates, balance sheet repositioning, cybersecurity, and competition - none of which directly relate to fair lending data reporting obligations.

BANRScore: 100%

BANNER CORP

Banner Corp operates as a federally insured commercial bank that originates small business loans, directly falling under Regulation B's requirements for covered financial institutions collecting small business lending data. The company's commercial banking services and loan origination activities align precisely with the rule's scope affecting financial institutions with covered credit transactions for small businesses. The rule focuses on small business lending compliance requirements and data collection for financial institutions, while the company's only identified risk is cybersecurity threats related to technology. There is no overlap between the regulatory compliance risks addressed by this rule and the company's cybersecurity risk profile.

BKUScore: 100%

BankUnited, Inc.

BankUnited operates as a bank holding company providing banking services and financial products to businesses in the United States, directly falling under the rule's jurisdiction as a covered financial institution engaged in small business lending. The company's core business model involves credit transactions with small businesses, making it subject to Regulation B's data collection and compliance requirements. The rule focuses on small business lending data collection compliance requirements, which does not align with the company's disclosed risk factors that primarily concern financial volatility, investment losses, and operational expenses. The company identifies only one regulatory compliance risk among its 28 total risks, indicating minimal exposure to this type of regulatory change.

BOKFScore: 100%

BOK FINANCIAL CORP

BOK Financial operates as a full-service banking institution with significant commercial banking operations that include lending to commercial customers, which directly aligns with the rule's focus on financial institutions with covered credit transactions for small businesses. The company's commercial banking segment would be subject to the small business lending data collection requirements under Regulation B. The rule's focus on regulatory compliance requirements for small business lending data collection has minimal alignment with BOK Financial's disclosed risk factors. While the company identifies regulatory approval as a risk category, this specific small business lending data rule does not directly address their top risks of asset quality deterioration, competitive pressure, cybersecurity, or interest margin decreases.

BUSEScore: 100%

FIRST BUSEY CORP /NV/

First Busey Corporation operates as a financial holding company providing banking services including loans and credit facilities, which directly aligns with the rule's focus on financial institutions with covered credit transactions for small businesses. The company's core business model involves lending activities that would require compliance with Regulation B's small business lending data collection requirements. The rule specifically targets financial institutions engaged in small business lending and data collection requirements under Regulation B. The company's risk factors focus entirely on technology, cybersecurity, and operational risks with no mention of lending activities, financial services regulation, or fair lending compliance, indicating no alignment with this rule's scope.

CMAScore: 100%

COMERICA INC /NEW/

Comerica operates as a major commercial bank with significant small business lending operations, directly falling under Regulation B's requirements for covered financial institutions. The company's commercial loan portfolio and banking operations involve extending credit to businesses, making it clearly subject to the small business lending data collection and compliance deadlines. The federal rule focuses exclusively on small business lending compliance requirements and data collection deadlines for financial institutions, while the company's only disclosed risk factor is cybersecurity threats in technology. There is no overlap between the rule's regulatory compliance impacts and the company's cybersecurity risk profile.

FCNCAScore: 100%

FIRST CITIZENS BANCSHARES INC /DE/

First Citizens BancShares operates as a financial institution with significant commercial banking and small business lending operations through its General Bank and Commercial Bank segments, directly falling under Regulation B's requirements for covered financial institutions collecting small business lending data. The company's capital adequacy processes and risk management framework indicate it would be subject to the rule's compliance deadlines and data collection mandates. The rule focuses on small business lending compliance requirements and data collection timelines for financial institutions, while the company's only disclosed risk factor is cybersecurity threats. There is no overlap between the regulatory compliance requirements of this lending rule and the company's technology cybersecurity risk profile.

FFBCScore: 100%

FIRST FINANCIAL BANCORP /OH/

First Financial Bancorp operates as a regional bank providing commercial and small business lending services, directly falling under Regulation B's scope for covered financial institutions with small business credit transactions. The company's core lending operations and geographic presence in regulated markets align perfectly with the rule's data collection and compliance requirements for small business lending. The rule directly addresses regulatory compliance risks in small business lending, which aligns with the company's identified regulatory compliance risks (6 risks) and financial risks (12 risks) related to loan demand and repayment. The extended compliance deadlines and data collection requirements specifically impact financial institutions' operational processes, matching the company's operational risk category (14 risks).

FHBScore: 100%

FIRST HAWAIIAN, INC.

First Hawaiian, Inc. operates as a financial institution providing banking services, which directly aligns with the rule's focus on covered financial institutions engaged in small business lending. The company's core business model involves credit transactions that would fall under Regulation B's requirements for data collection and reporting on small business lending activities. The rule primarily addresses regulatory compliance requirements for small business lending data collection, while the company's risk profile focuses on financial metrics like deposit costs and net interest income with minimal regulatory compliance risks identified. There is weak alignment as the rule's compliance burden could indirectly affect operational expenses, but this is not a primary risk concern for the company.

FHNScore: 100%

FIRST HORIZON CORP

First Horizon Corp operates as a regional bank providing commercial and small business lending services, directly falling under Regulation B's scope for covered financial institutions. The company's extensive small business lending operations would require compliance with the data collection and reporting requirements for covered credit transactions. The rule's regulatory compliance requirements show weak alignment with the company's single identified regulatory risk factor. While the company acknowledges regulatory changes as a risk, this specific small business lending data collection rule would only minimally impact their operations given their primary focus on mortgage lending and bond trading rather than small business credit.

FIBKScore: 100%

FIRST INTERSTATE BANCSYSTEM INC

First Interstate BancSystem is a regional bank holding company that provides commercial and small business lending services, directly falling under the rule's coverage of financial institutions with covered credit transactions for small businesses. The company's core lending operations and geographic presence in multiple states align perfectly with Regulation B's requirements for small business lending data collection and compliance. The rule focuses on small business lending data collection compliance requirements, which does not align with the company's disclosed interest rate and liquidity/capital risks. The company's risk profile shows no mention of regulatory compliance, fair lending, or data collection challenges that would be affected by this Regulation B extension.

FITBIScore: 100%

FIFTH THIRD BANCORP

Fifth Third Bancorp is a banking and lending institution that originates credit transactions for small businesses, directly falling under the rule's coverage as a financial institution required to collect and report small business lending data under Regulation B. The company's core business model of banking and lending aligns perfectly with the rule's requirements for covered financial institutions. The rule primarily addresses regulatory compliance and data collection requirements for small business lending, which does not align with the company's disclosed risk factors focused on credit quality deterioration, liquidity maintenance, and dividend constraints. There is minimal overlap as the company's single regulatory compliance risk is generic and not specifically tied to fair lending or small business data collection requirements.

FRMEScore: 100%

FIRST MERCHANTS CORP

First Merchants Corp operates as a banking and financial services institution, directly falling under the scope of Regulation B which targets financial institutions with covered credit transactions for small businesses. The company's core business model involves lending activities that would require compliance with the small business lending data collection and reporting requirements. The rule's primary impact on regulatory compliance costs and operational requirements for small business lending data collection has weak alignment with the company's single 'Regulatory Changes' risk factor. However, the company's 'Nonperforming Assets Increase' risk shows some indirect relevance as the rule aims to improve fair lending transparency that could affect loan portfolio quality.

FULTScore: 100%

FULTON FINANCIAL CORP

Fulton Financial Corp operates as a regional bank holding company providing commercial banking services including small business lending, which directly falls under Regulation B's requirements for covered financial institutions collecting small business lending data. The company's core business of originating credit transactions to small businesses aligns perfectly with the rule's scope and compliance obligations. The rule focuses on small business lending data collection requirements under ECOA Regulation B, which does not align with any of the company's disclosed risk factors. The company's risks center around dividend restrictions, equity compensation, and shareholder value dilution, none of which relate to consumer lending compliance or small business credit data reporting.

GBCIScore: 100%

GLACIER BANCORP, INC.

Glacier Bancorp is a financial institution that originates small business loans through its banking subsidiaries, directly falling under Regulation B's requirements for covered financial institutions collecting small business lending data. The company's core business of commercial lending to small businesses aligns perfectly with the rule's scope and compliance obligations. The rule focuses on small business lending data collection compliance requirements under Regulation B, which does not align with the company's identified risk of allowance for credit losses estimation. The company's financial risk relates to accounting estimates and financial statement impacts, while the rule addresses regulatory reporting and compliance deadlines for lending institutions.

HBANScore: 100%

HUNTINGTON BANCSHARES INC /MD/

Huntington Bancshares operates as a financial institution that provides small business banking services, including covered credit transactions for small businesses, which directly falls under the scope of Regulation B's small business lending data collection requirements. The company's commercial banking segment specifically engages in small business lending activities that would require compliance with the extended deadlines and data reporting obligations. The rule focuses on small business lending data collection compliance requirements, which does not directly align with any of the company's identified top risks. The company's single regulatory compliance risk is generic and not specifically tied to lending data reporting, while its primary concerns are credit loss estimation, interest rates, and loan portfolio quality rather than fair lending data collection.

HWCScore: 100%

HANCOCK WHITNEY CORP

Hancock Whitney Corporation operates Hancock Whitney Bank, which provides commercial and small business banking services including lending products. As a financial institution offering small business credit transactions, it falls directly under the scope of Regulation B's small business lending data collection requirements for covered financial institutions. The rule primarily addresses compliance and fair lending data collection requirements for small business lending, which does not align with the company's identified high-impact risks of information systems interruption, cybersecurity, liquidity, and deposit runs. The company's risk profile focuses on operational and financial stability threats rather than regulatory compliance data reporting obligations.

JPMScore: 100%

JPMORGAN CHASE & CO

JPMorgan Chase operates as a major financial institution with extensive small business lending operations through its Consumer & Community Banking and Commercial & Investment Bank segments, directly falling under Regulation B's requirements for covered financial institutions collecting small business lending data. The rule focuses on small business lending data collection and fair lending compliance, which does not align with the company's primary risk factors of fair value estimation, consolidation of VIEs, and accounting standards. The company's regulatory compliance risks (28 identified) are generic and not specifically related to consumer lending or ECOA requirements.

KEYScore: 100%

KEYCORP /NEW/

KeyCorp operates as a bank holding company through KeyBank, directly engaging in small business lending activities that fall under Regulation B's requirements for covered financial institutions. The company's core banking services include originating credit transactions for small businesses, making it clearly subject to the rule's data collection and compliance obligations. The rule focuses on small business lending data collection compliance deadlines, which does not align with the company's primary risk factors of cybersecurity threats, third-party vulnerabilities, and information security program effectiveness. While there is a general regulatory compliance risk category mentioned, the specific nature of this lending regulation does not address the company's identified technology and cybersecurity-focused risks.

ONBScore: 100%

OLD NATIONAL BANCORP /IN/

Old National Bancorp operates as a financial institution offering banking services, including overdraft protection programs, which fall under the scope of Regulation B's small business lending requirements. As a covered financial institution, it would be required to comply with the data collection and reporting mandates for small business credit transactions. The rule directly addresses the company's 'Compliance and Regulatory Risk' by imposing new data collection and reporting requirements for small business lending, which could lead to legal penalties and reputational damage if not properly implemented. It also intersects with 'Privacy and Data Governance' risk through mandatory collection of protected demographic information, requiring enhanced data management protocols to avoid regulatory penalties.

PFSScore: 100%

PROVIDENT FINANCIAL SERVICES INC

Provident Financial Services operates as a bank holding company with extensive small business lending operations through commercial loans, commercial real estate loans, and construction loans, directly falling under Regulation B's requirements for covered financial institutions collecting small business lending data. The company's core business model of originating loans to businesses and its regulatory status as a federally regulated bank make it clearly subject to these compliance requirements. The rule focuses specifically on small business lending data collection compliance requirements, while the company's regulatory risk factor is generic and mentions 'legal proceedings and claims' without specifying lending or fair credit practices. There is minimal overlap as the company's identified regulatory risk appears broader and not directly tied to consumer financial protection or credit reporting obligations.

PNCScore: 100%

PNC FINANCIAL SERVICES GROUP, INC.

PNC is a major financial institution with extensive small business lending operations, directly falling under Regulation B's requirements for covered financial institutions. The company's core business activities include originating covered credit transactions for small businesses, making it subject to all compliance deadlines and data collection mandates. The rule primarily addresses regulatory compliance and operational risks related to small business lending data collection, which does not align with the company's top risks of operational risk management, financial derivatives, and information security. While the company has identified regulatory change and compliance risks, these are not specific to consumer financial protection or lending activities.

PPBIScore: 100%

PACIFIC PREMIER BANCORP INC

Pacific Premier Bancorp operates as a financial institution engaged in lending activities, which directly falls under the scope of Regulation B's small business lending requirements. As a bank, it would be required to collect and report small business lending data, making it clearly affected by these compliance obligations. The rule's focus on small business lending data collection and compliance deadlines has minimal alignment with the company's disclosed risk factors. While the company identifies regulatory scrutiny as a risk, this specific small business lending rule does not address their primary concerns around interest rates, economic conditions, deposit attrition, or real estate market declines.

SFBSScore: 100%

ServisFirst Bancshares, Inc.

ServisFirst Bancshares operates as a bank holding company providing commercial banking services including small business lending, directly falling under Regulation B's scope for covered financial institutions. The company's core business of originating credit transactions to small businesses aligns perfectly with the rule's data collection and compliance requirements for small business lending. The rule focuses on small business lending compliance requirements and data collection timelines for financial institutions, while the company's only identified risk is cybersecurity threats related to technology. There is no overlap between the regulatory compliance requirements of this lending rule and the company's cybersecurity risk profile.

SFNCScore: 100%

SIMMONS FIRST NATIONAL CORP

Simmons First National Corp operates as a banking and financial services institution, directly falling under the scope of Regulation B's small business lending requirements. As a financial institution providing credit services, it would be required to comply with the small business lending data collection and reporting mandates affecting covered financial institutions. The rule focuses on small business lending data collection compliance requirements under ECOA Regulation B, while the company's risk factors primarily address financial accounting, credit loss estimation, and tax law interpretation with no mention of fair lending, consumer protection, or small business lending compliance risks. The single regulatory compliance risk identified relates to income tax law interpretation, which does not overlap with the small business lending data collection requirements of this rule.

SNVScore: 100%

SYNOVUS FINANCIAL CORP

Synovus Financial Corp operates as a regional bank providing commercial and consumer banking services, including small business lending, which directly falls under Regulation B's requirements for covered financial institutions. The company's core business of originating credit transactions to small businesses aligns perfectly with the rule's data collection and compliance mandates for financial institutions. The rule's focus on small business lending data collection and compliance deadlines has minimal alignment with the company's disclosed risk factors of funding availability and client confidence erosion. While the rule could indirectly affect financial institutions' operational costs, it does not directly address the specific funding or market confidence risks identified by the company.

UBSIScore: 100%

UNITED BANKSHARES INC/WV

United Bankshares operates as a financial institution with significant commercial lending activities, including commercial, financial & agricultural loans ($151M revenue) and construction & land development loans ($64M revenue), which directly fall under the rule's coverage of small business lending. The company's core business model involves originating credit transactions to businesses, making it clearly subject to Regulation B's data collection and compliance requirements for covered financial institutions. The rule primarily addresses regulatory compliance requirements for small business lending data collection, while the company's disclosed risks focus on loan losses, acquisition integration, economic trends, mortgage consolidation, and data security with only one general regulatory compliance risk mentioned. There is minimal direct overlap as the company's specific regulatory risk isn't detailed enough to align with this particular small business lending data collection mandate.

WAFDScore: 100%

WAFD INC

WAFD Inc operates as a commercial bank with significant small business lending operations through its $13.1B commercial loans segment, directly falling under Regulation B's coverage of financial institutions with covered credit transactions for small businesses. The company's core business model of lending to mid-sized businesses and commercial real estate developers aligns perfectly with the rule's requirements for collecting small business lending data and demographic information. The rule focuses on small business lending compliance requirements and fair lending data collection, which are unrelated to cybersecurity threats. The company's sole identified risk category (technology cybersecurity) shows no overlap with the rule's focus on regulatory compliance deadlines and lending data reporting.

WALScore: 100%

WESTERN ALLIANCE BANCORPORATION

Western Alliance Bancorporation operates as a financial institution providing loans to businesses, including small businesses, which directly falls under the scope of Regulation B's small business lending data collection requirements. The company's core lending operations would require compliance with the extended deadlines for collecting and reporting small business lending application data to the CFPB. The rule focuses on small business lending data collection requirements under Regulation B, which does not directly address the company's primary risk factors of CRE market exposure, charge-offs, FDIC assessments, CECL transition, or foreclosure issues. The only minimal alignment exists with the regulatory compliance risk category, but this rule specifically targets small business lending data reporting rather than the broader regulatory capital or assessment concerns identified by the company.

WTFCScore: 100%

WINTRUST FINANCIAL CORP

Wintrust Financial Corp operates as a commercial lender providing banking and financial services, directly aligning with the rule's focus on financial institutions with covered credit transactions for small businesses. The company's commercial lending segment would be subject to the small business lending data collection requirements under Regulation B. The rule focuses on compliance requirements for small business lending data collection and fair lending practices, which do not align with the company's disclosed risk factors centered on interest rate fluctuations, asset-liability mismatches, and inflation impacts. There is minimal overlap as the company's risks are primarily financial and market-based rather than regulatory compliance or lending operation-focused.

ZIONScore: 100%

ZIONS BANCORPORATION, NATIONAL ASSOCIATION /UT/

Zions Bancorporation is a banking institution that provides lending services to small businesses in the Western United States, directly falling under the scope of Regulation B's small business lending requirements. As a financial institution with covered credit transactions for small businesses, it would be required to comply with the data collection and reporting mandates outlined in the rule. The rule focuses on compliance requirements for small business lending data collection and fair lending practices, which does not directly address any of the company's identified risk factors. The company's risks center on credit quality deterioration, cybersecurity threats, operational disruptions, talent retention, and counterparty concentration - none of which overlap with the regulatory compliance burdens imposed by this lending data collection rule.