Small Business Lending Company Moratorium Rescission and Removal of the Loan Requirement Authorization
January 3, 2023
On November 7, 2022, Volume 87, No. 214 of the Federal Register contained a Notice of Proposed Rulemaking on Small Business Lending Company (SBLC) Moratorium Rescission and Removal of the Requirement for a Loan Authorization (87 FR 66963).1 The proposed rule, if implemented, will lift the moratorium on licensing new Small Business Lending Companies (SBLCs), add a new type of entity called a Mission-Based SBLC, and remove the requirement for a Loan Authorization.
The African American Alliance of CDFI CEOs (the Alliance) is pleased to provide the following comments in response to the Proposed Rulemaking, 87 FR 66963. The Alliance is a membership- driven intermediary organization that aims to: build the capacity of member organizations; build bridges to economic stability, well- being, and wealth for Black individuals, families, and communities; and build power in Black communities by challenging and influencing financial sectors to operate more equitably. Since launching in 2018, the Alliance has established a network of 72 CEOs of Black-led Community Development Financial Institutions (CDFIs), which includes loan funds, credit unions, and venture capital funds. Alliance members reach historically underserved communities in all 50 states by providing financial services in the small business, affordable housing, and commercial real estate development sectors.
