---
title: Section 1071 Compliance Update for June 2025
description: The CFPB has extended the compliance dates for its small business lending rule (Section 1071 of the Dodd-Frank Act). This post covers the latest changes.
---

[Premier Insights ](https://www.premierinsights.com/blog)

# [Section 1071 Compliance Update for June 2025](https://www.premierinsights.com/blog/section-1071-compliance-update-for-june-2025)

 Written by [Premier Insights](https://www.premierinsights.com/blog/author/premier-insights) | Jun 20, 2025 4:18:45 PM

The Consumer Financial Protection Bureau (CFPB) has extended the compliance dates for its small business lending rule (Section 1071 of the Dodd-Frank Act), which amends Regulation B, due to ongoing litigation and court orders. This interim final rule revises the compliance and reporting timelines for covered financial institutions.

## Revised Section 1071 Compliance Deadlines

Here is a table outlining the revised compliance dates, required data collection periods, and first filing deadlines:

| **Compliance Tier** | **New Compliance Date** | **Required Data Collection Period** | **New First File Deadline** |
| --- | --- | --- | --- |
| **Highest Volume Lenders (Tier 1)** | July 1, 2026 | July 1, 2026 – December 31, 2026 | June 1, 2027 |
| **Moderate Volume Lenders (Tier 2)** | January 1, 2027 | January 1, 2027 – December 31, 2027 | June 1, 2028 |
| **Smallest Volume Lenders (Tier 3)** | October 1, 2027 | October 1, 2027 – December 31, 2027 | June 1, 2028 |

 

## Key Details:

- **Determination of Compliance Tier:** Financial institutions can determine their compliance tier by using their small business originations from either 2022 and 2023, or 2023 and 2024, or 2024 and 2025.
- **Origination Thresholds for Each Tier:** Once the reference years are selected, the number of covered credit transactions originated in *both* years determines the tier: 
    - **Highest Volume Lenders (Tier 1):** Institutions that originated at least **2,500** covered credit transactions in *both* of the chosen calendar years fall into Tier 1. Their new compliance date is July 1, 2026.
    - **Moderate Volume Lenders (Tier 2):** Institutions not in Tier 1 that originated at least **500** covered credit transactions in *both* of the chosen calendar years fall into Tier 2. Their new compliance date is January 1, 2027.
    - **Smallest Volume Lenders (Tier 3):** Institutions not in Tier 1 or Tier 2 that originated at least **100** covered credit transactions in *both* of the chosen calendar years fall into Tier 3. Their new compliance date is October 1, 2027.
- **Voluntary Early Data Collection:** Covered financial institutions are permitted to begin collecting protected demographic data required under the 2023 final rule 12 months before their new compliance date to test their procedures and systems. 
    - Tier 1 institutions may begin collecting protected demographic information on or after July 1, 2025.
    - Tier 2 institutions may begin on or after January 1, 2026.
    - Tier 3 institutions may begin on or after October 1, 2026.
- **Anticipation of New Rulemaking:** The CFPB has noted in the litigation that it "intends to initiate a new Section 1071 rulemaking and anticipates issuing a notice of proposed rulemaking as expeditiously as reasonably possible". This current interim final rule's extension is also intended to provide time for the CFPB "to issue a new proposal to reconsider certain aspects of the 2023 final rule".

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