User testing for sample data collection form for the small business lending final rule
On March 30, 2023, the Consumer Financial Protection Bureau (CFPB) released a final rule to amend Regulation B to implement changes to the Equal Credit Opportunity Act made by section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Consistent with section 1071, the CFPB is requiring covered financial institutions to collect and report to the data on applications for credit for small businesses, including those that are owned by women or minorities. The data includes information (the “protected demographic information”) about a small business applicant’s status as a minority-owned, women-owned, and/or LGBTQI+-owned business and about the applicant’s principal owners’ ethnicity, race, and sex.
Following the release of the NRPM, the CFPB, after the appropriate notice in the Federal Register, and a thirty-day comment period, sought and received OMB approval to conduct several rounds of message and user testing research related to the sample form and other aspects of this rule. The CFPB conducted qualitative research to learn about small business owners’ likely experience in filling out the sample data collection form. The qualitative research also explored design and language options to potentially increase small business applicants’ willingness to fill out the form.
This report summarizes the results of that testing. The feedback gathered in the process of these testing efforts numbered among the various considerations of the CFPB in the development of the final rule.