Compliance dates for 1071 will be enforced on a tier system. According to a release from the CFPB in June of this year, the final rule, which was to become effective August 29, 2023, was subject to a stay by a federal Texas court pending the outcome of the Supreme Court decision in CFPB v. CFSA. The interim final rule extends compliance dates to July 18, 2025, for Tier 1 institutions, June January 16, 2026 for Tier 2 institutions, and October 18, 2026 for Tier 3 institutions. Please refer to the table below for detailed information regarding tier definitions, compliance dates, and first filing dates.
| Tier Definitions | Compliance Date | First Filing Date |
| Tier 1 (originated more than 2,500 covered credit transactions in both calendar years 2022 and 2023) | July 18, 2025 | June 1, 2026 |
| Tier 2 (originated more than 500 covered credit transactions in 2022 and 2023 or originated more than 100 covered credit transactions in 2024) | January 16, 2026 | June 1, 2027 |
| Tier 3 (originated more than 100 covered credit transactions in both 2024 and 2025) | October 18, 2026 | June 1, 2027 |
