Frequently Asked Questions


Frequently Asked Questions (FAQs)

About CRBF’s Code of Ethics and Best Practices


Q:  What is the Coalition for Responsible Business Finance (CRBF)?

A:  The Coalition for Responsible Business Finance (CRBF) is a group of businesses and service providers that advocate for the development of a large, diverse, and ethical marketplace for Non-Bank Small Business (NBSB) financing products.  CRBF was created to educate state and federal policymakers, media, and communities on how the NBSB market is driving innovation and providing small businesses access to capital that is necessary for economic growth and the health of the small business economy.  The Coalition's purpose is to bolster the trust and credibility of this growing industry through responsible business practices while ensuring that NBSB products and services meet the needs of America's small business community.


Q:  Who are members of CRBF?

A:  CRBF member-companies represent a broad cross-section of the FinTech community that serves small business.  The members are Fundation, PayNet, Orion First, The Business Backer, Breakout Capital, and Provider Web.  CRBF is the only coalition that has representatives that include financing providers, a commercial loan and lease servicing company, and a leading credit data provider.


Q:  Who is on CRBF’s Advisory Board?

A:  CRBF believes it’s important for both lenders and small business advocates too come together to discuss issues and solve challenges related to small business lending. As such, our Advisory Board includes lending and finance experts, small business owners, and organizations that represent and advocate for small business in Washington, DC and in state capitols. CRBF’s Advisory Board includes Nick Owens from Magnolia Strategy Partners, Robert Cook from Hudson Cook, Rick Eckman from Pepper Hamilton, Sam Graziano from Fundation, Jim Salters from The Business Backer,  Holly Wade from NFIB,  Todd McCracken from NSBA,  Karen Kerrigan from SBE Council,  and Chris Walters from SBIA.


Q: How do I join CRBF?

A:  CRBF welcomes leaders from various institutional stakeholders through the Non-Bank Small Business (NBSB) industry and banking institutions who epitomize responsible practices and a commitment to serving small businesses.  Contact Executive Director Tom Sullivan for membership information.


Q:  Who is CRBF’s Executive Director?

A:  Tom Sullivan is an attorney in the government relations practice of Nelson Mullins Riley & Scarborough, LLP, a law firm with offices in Florida, Georgia, So. Carolina, No. Carolina, Tennessee, West Virginia, Massachusetts, New York, and Washington, DC.   Prior to re-joining Nelson Mullins, Tom served as the General Counsel for the Bipartisan Policy Center (BPC), a non-profit organization founded in 2007 by former Senate Majority Leaders Howard Baker, Tom Daschle, Bob Dole, and George Mitchell.  Mr. Sullivan served under President George W. Bush and was unanimously confirmed by the Senate to advocate the views and needs of small business before government agencies and Congress.  As Chief Counsel for Advocacy in the Small Business Administration (SBA), Tom testified frequently before state legislatures and congressional committees and was directly involved in over 100 regulatory and legislative matters. 


Q:  Why is CRBF publishing a Code of Ethics and Best Practices?

A:  CRBF was launched in January with a mission to educate policymakers on the value of the Non-Bank Small Business (NBSB) financing market.  The Coalition’s purpose is to bolster the trust and credibility of NBSB lending and financing through responsible business practices.  These Best Practices provide details, at an operational level, on what CRBF members believe are responsible business practices and could serve as an initial framework for future federal regulation of the industry.


Q:  How are CRBF’s Best Practices different from similar efforts?

A:  CRBF membership spans across various parts of the Non-Bank Small Business (NBSB) industry. Given the diverse range of input, CRBF’s Best Practices cover an array of products and solutions that small business owners may be considering. Additionally, CRBF believes that a successful transaction depends on both responsible providers or facilitators of capital, as well as responsible small business borrowers.  CRBF relies on the input of small business advocacy organizations like NSBA, the SBE Council, NFIB, and SBIA through its Advisory Board and has incorporated the Advisory Board’s views into the Best Practices.


Q:  How will CRBF members disclose the cost of each financial product?

A:  CRBF Best Practices help small businesses compare costs by ensuring full disclosure of costs and fees.  CRBF members will disclose, at a minimum, two approved measurements of cost, such as Annual Percentage Rate (“APR”) and Total Contractual Amount. Additionally, CRBF is supporting the SMART Box initiative focused on developing an industry-wide model disclosure that will help small businesses more effectively comparison shop for capital. 

While the CRBF Best Practices help small businesses compare costs by ensuring thorough disclosure of costs and fees, the coalition is also participating in the Innovative Lending Platform Association’s SMART Box initiative focused on developing an industry-wide model disclosure that will help small businesses comparison shop for additional capital.


Q:  Does CRBF support the codification of its Best Practices into state or federal laws?

A:  CRBF members embrace the concept of a federal regulatory system that enhances transparency and disclosure and empowers small business owners to make good financial decisions.  CRBF believes that a federal regulatory system must:

a) Clearly distinguish between consumer lending and commercial lending; and

b) Be centralized in an agency fully supportive of small business financing providers and customers; and

c) Rely on the input of small business stakeholders outside of the financial services industry; and

d) Include reciprocity for state licensure, registration, and permitting requirements.

CRBF also believes that lawmakers at a state and federal level should not consider requirements that impose one-size-fits-all standards on an innovative industry that seeks to tailor its products and services to meet the needs of an ever-changing small business customer base.


Q:  Are CRBF’s Best Practices enforceable?

A:  The Best Practices are commitments made by CRBF member-company CEOs to demonstrate leadership and raise standards within the industry.  Once CRBF becomes a non-profit association, its bylaws will include enforceable best practices.  For more information, please contact CRBF’s Executive Director.


Q:  Will CRBF’s Best Practices change?

A:  Yes, CRBF will adjust its best practices to incorporate value-added input from future CRBF members and the small business community.