Bill Overview
Title: To require the Bureau of Consumer Financial Protection to issue a before deleting or modifying certain small business loan data, and for other purposes.
Description: This bill requires the Consumer Financial Protection Bureau to issue a rule prior to deleting or modifying publicly available small business loan data due to privacy concerns. Specifically, the bureau must describe the intended modifications and deletions and explain how such modifications and deletions will advance a privacy interest.
Sponsors: Rep. Luetkemeyer, Blaine [R-MO-3]
Target Audience
Population: Small business owners and related stakeholders
Estimated Size: 25000000
- The bill primarily concerns the actions of the Bureau of Consumer Financial Protection regarding modifications to small business loan data.
- Small business owners are directly impacted as the data pertains to their loan activities.
- Financial institutions that lend to small businesses will be impacted by changes in reporting or data management.
- Consumer privacy advocates and organizations monitoring financial transparency may also be affected due to changes in data availability.
- The general public, indirectly, as transparency in small business lending data is important for public awareness and economic research.
Reasoning
- This policy primarily impacts small business owners who depend on transparent and accurate small business loan data. It would ensure that any changes to public data are made with consideration of privacy implications, potentially benefiting those concerned about privacy.
- Financial institutions that manage small business loans might be affected as well, as they rely on transparency of data for risk assessment and loan processing.
- Privacy advocates may see this policy as positive because it provides a structured consideration of privacy impacts before data is modified.
- Consumer transparency advocates could be concerned if data modifications reduce public oversight capabilities.
- The general population may see indirect effects through changes in the economic environment due to differing transparency levels in small business operations.
Simulated Interviews
Small Business Owner (Chicago, IL)
Age: 35 | Gender: male
Wellbeing Before Policy: 7
Duration of Impact: 5.0 years
Commonness: 8/20
Statement of Opinion:
- I appreciate the importance of privacy, but I'm also concerned about less transparency in loan data which might affect my ability to compare loan options.
- It's essential that any data modification doesn't hide important trends that could impact my business.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 6 | 7 |
| Year 2 | 6 | 7 |
| Year 3 | 6 | 7 |
| Year 5 | 5 | 7 |
| Year 10 | 5 | 6 |
| Year 20 | 5 | 6 |
Privacy Advocate (Seattle, WA)
Age: 45 | Gender: female
Wellbeing Before Policy: 6
Duration of Impact: 10.0 years
Commonness: 5/20
Statement of Opinion:
- This policy is a step in the right direction for ensuring business data privacy.
- I'm hopeful that these changes will lead to less unnecessary data exposure, and I'm supportive of the bureau's role in this.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 7 | 6 |
| Year 2 | 8 | 6 |
| Year 3 | 8 | 6 |
| Year 5 | 8 | 6 |
| Year 10 | 8 | 6 |
| Year 20 | 8 | 6 |
Bank Executive (New York, NY)
Age: 52 | Gender: female
Wellbeing Before Policy: 8
Duration of Impact: 5.0 years
Commonness: 6/20
Statement of Opinion:
- Ensuring privacy is crucial, but we need transparent access to modify plans for lending risks.
- If data deletion compromises our analysis ability, it could hinder decision-making capabilities.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 6 | 8 |
| Year 2 | 6 | 8 |
| Year 3 | 5 | 8 |
| Year 5 | 5 | 8 |
| Year 10 | 5 | 7 |
| Year 20 | 5 | 7 |
Tech Startup Founder (Austin, TX)
Age: 29 | Gender: male
Wellbeing Before Policy: 7
Duration of Impact: 3.0 years
Commonness: 4/20
Statement of Opinion:
- I'm worried how restricted access to loan data might affect our product’s data insights feature.
- Privacy is important, but so is complete and reliable data access for developers.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 5 | 7 |
| Year 2 | 5 | 7 |
| Year 3 | 5 | 7 |
| Year 5 | 6 | 8 |
| Year 10 | 6 | 8 |
| Year 20 | 7 | 8 |
Financial Analyst (Los Angeles, CA)
Age: 60 | Gender: male
Wellbeing Before Policy: 9
Duration of Impact: 6.0 years
Commonness: 7/20
Statement of Opinion:
- If crucial data is hidden, it could make market trend analysis less accurate.
- While privacy needs to be a top priority, transparency is equally important for economic assessments.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 7 | 9 |
| Year 2 | 7 | 9 |
| Year 3 | 6 | 9 |
| Year 5 | 6 | 9 |
| Year 10 | 6 | 8 |
| Year 20 | 6 | 8 |
Economic Researcher (Denver, CO)
Age: 39 | Gender: female
Wellbeing Before Policy: 7
Duration of Impact: 10.0 years
Commonness: 5/20
Statement of Opinion:
- Changes in data availability could reduce our confidence in economic impact outputs.
- Protection of privacy is necessary, but accessibility must not be compromised.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 6 | 7 |
| Year 2 | 6 | 7 |
| Year 3 | 6 | 7 |
| Year 5 | 6 | 7 |
| Year 10 | 7 | 7 |
| Year 20 | 7 | 7 |
Small Business Lender (Boston, MA)
Age: 30 | Gender: other
Wellbeing Before Policy: 8
Duration of Impact: 4.0 years
Commonness: 6/20
Statement of Opinion:
- Data clarity is necessary to ensure we provide the best rates.
- While protecting privacy, we need clear guidelines to operate fairly.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 5 | 8 |
| Year 2 | 5 | 8 |
| Year 3 | 5 | 8 |
| Year 5 | 5 | 8 |
| Year 10 | 5 | 7 |
| Year 20 | 6 | 7 |
Regulatory Affairs Specialist (Houston, TX)
Age: 50 | Gender: male
Wellbeing Before Policy: 8
Duration of Impact: 2.0 years
Commonness: 5/20
Statement of Opinion:
- Incorporating privacy measures is part of our compliance efforts.
- Clear rules on data changes will help us maintain regulatory compliance without excessive risk.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 8 | 8 |
| Year 2 | 8 | 8 |
| Year 3 | 8 | 8 |
| Year 5 | 8 | 8 |
| Year 10 | 8 | 8 |
| Year 20 | 8 | 8 |
Retired Teacher (Miami, FL)
Age: 63 | Gender: female
Wellbeing Before Policy: 6
Duration of Impact: 5.0 years
Commonness: 8/20
Statement of Opinion:
- I'm new to business loans and need to learn the ropes. Data unclarity might make it more difficult.
- I support privacy efforts, but finding the right loan is hard enough as it is.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 5 | 6 |
| Year 2 | 5 | 6 |
| Year 3 | 5 | 6 |
| Year 5 | 5 | 6 |
| Year 10 | 5 | 6 |
| Year 20 | 5 | 6 |
Community Organizer (Nashville, TN)
Age: 41 | Gender: female
Wellbeing Before Policy: 7
Duration of Impact: 5.0 years
Commonness: 7/20
Statement of Opinion:
- Transparency is key to understanding community economic dynamics.
- The policy looks good for privacy, but we must ensure impact doesn't reduce transparency essential for local development.
Wellbeing Over Time (With vs Without Policy)
| Year | With Policy | Without Policy |
|---|---|---|
| Year 1 | 6 | 7 |
| Year 2 | 6 | 7 |
| Year 3 | 7 | 7 |
| Year 5 | 7 | 7 |
| Year 10 | 7 | 7 |
| Year 20 | 7 | 7 |
Cost Estimates
Year 1: $10000000 (Low: $8000000, High: $12000000)
Year 2: $8000000 (Low: $6000000, High: $10000000)
Year 3: $8000000 (Low: $6000000, High: $10000000)
Year 5: $5000000 (Low: $4000000, High: $6000000)
Year 10: $1000000 (Low: $800000, High: $2000000)
Year 100: $100000 (Low: $50000, High: $200000)
Key Considerations
- Implementation costs are primarily administrative and involve the development of new processes and rule-making for data handling.
- The duration of economic impacts, particularly on GDP and tax revenue, is speculative and based on indirect mechanisms.
- Stakeholders such as small businesses and financial institutions need to be engaged to ensure that the implementation of the rules is feasible and does not unduly burden these entities.