Shaping Small Business Lending Policy Through Matched-Pair Mystery Shopping

Abstract

With limited financial sophistication, entrepreneurial consumers approach the financial marketplace more like retail financial consumers than like business customers. However, an assumption of both legislators and regulators is that business borrowers are more financially savvy than consumer borrowers and thus do not require protections that are as broad reaching. This gap between marketplace policy protections and the lived reality of the vast majority of small business entrepreneurs sets the stage for entrepreneurial consumers to fall through the regulatory cracks, creating the potential for exploitation and abuse. This situation may be exacerbated for minority entrepreneurs, who belong to protected classes that generally are more vulnerable to exploitation in marketplaces, including the small business lending marketplace. This article details the current status of the policy gap relative to minority entrepreneurial consumers and presents a matched-pair mystery shopping study to demonstrate the critical need for reliable, primary data to inform regulatory agencies as they work to implement appropriate protections to ensure equal access to credit across the small business lending marketplace.