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Financial Services Law Insights and Observations

CFPB to extend 1071 rule compliance deadlines

Federal Issues Agency Rule-Making & Guidance CFPB Small Business Lending Texas

Federal Issues

On May 17, the CFPB announced it is extending the compliance deadlines for the small business lending rule (Section 1071 of Dodd-Frank, the “1071 rule”), which will require financial institutions to collect and report data on lending to small businesses to the Bureau (covered by InfoBytes here). Following challenges to the 1071 rule in the U.S. District Court in Texas, the rule was stayed pending the Supreme Court’s decision in CFPB v. CFSA (covered by InfoBytes here). Considering the Supreme Court’s recent decision that the Bureau’s funding is constitutional and the district court’s order requiring the CFPB to extend the rule’s compliance deadlines to compensate for the period stayed, the Bureau will issue an interim final rule to extend compliance deadlines as follows:

  • Tier 1 institutions (highest volume lenders): The new compliance date is July 18, 2025, and the first filing deadline is June 1, 2026.
  • Tier 2 institutions (moderate volume lenders): The new compliance date is January 16, 2026, and the first filing deadline is June 1, 2027.
  • Tier 3 institutions (lowest volume lenders): The new compliance date is October 18, 2026, and the first filing deadline is June 1, 2027.