Dodd Frank Section 1071 Small Business Data Collection Rule Postponed

On June 18, 2025, the CFPB published an interim final rule effective on July 18, 2025, postponing the effective date of Regulation B implementation of the Section 1071 Small Business Data Collection Rule.

The summary states: In light of court orders in ongoing litigation, the Consumer Financial Protection Bureau (CFPB or Bureau) is amending Regulation B to extend the compliance dates set forth in its 2023 Small Business Lending Rule, as amended by a 2024 interim final rule, and to make other date-related conforming adjustments.

The CFPB is extending the revised compliance dates by approximately one year. Therefore, covered financial institutions must begin collecting data as follows:

Compliance Tier	Original Compliance Date in the 2023 Final Rule	Revised Compliance Date in the 2024 Interim Final Rule	New Compliance Date	New First Filing Deadline
Highest Volume Lenders (Tier 1 – at least 2,500)	October 1, 2024	July 18, 2025	July 1, 2026	June 1, 2027
Moderate Volume Lenders (Tier 2 – at least 500)	April 1, 2025	January 16, 2026	January 1, 2027	June 1, 2028
Smallest Volume Lenders (Tier 3 – at least 100)	January 1, 2026	October 18, 2026	October 1, 2027	June 1, 2028

Covered financial institutions are permitted to continue using their Small Business originations from 2022 and 2023 to determine their compliance tier, or they may instead use their originations from 2023 and 2024, or from 2024 and 2025.

Covered financial institutions are permitted to begin collecting protected demographic data required under the 2023 final rule 12 months before their new compliance date, in order to evaluate their procedures and systems.

As illustrated above, the deadline for submitting Small Business Lending data will remain June 1 following the calendar year for which data is collected. Finally, the CFPB is updating its grace period policy statement to reflect the revised compliance dates.

While changes may be coming, they’re not gone yet. You can depend on TCA for A Better Way to keep you informed on all things compliance, BSA, CRA and fair lending. Contact us at (800) 934-7347 or at [email protected].

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