Compliance Deadlines for Small Business Lending Rule Extended 

JUL 08, 2025 | PRACTUS LLP

Compliance Deadlines for Small Business Lending Rule Extended 

Authored by Andrea J. Shaw

CFPB Issues Final Rule to Implement Section 1071 of Dodd-Frank Act 

On June 18, 2025, the Consumer Financial Protection Bureau (CFPB) extended small business lending rule compliance deadlines. The small business lending rule amended Regulation B of the Equal Credit Opportunity Act pursuant to Section 1071 of the Dodd Frank Act or the 1071 Rule. Litigation involving the CFPB delayed the original rule’s compliance deadlines in 2024. Although the litigation resolved in May of 2024, the CFPB just updated the compliance dates this month. Here is a chart showing the new compliance deadlines as well as the previous changes:

Compliance Tier 2023 Original Compliance Date 2024 Interim Final Rule Compliance Dates 2025 Interim Final Rule Compliance Date New First Filing Deadline 
Highest Volume (Tier 1) October 1, 2024 July 18, 2025 July 1, 2026 June 1, 2027 
Moderate Volume (Tier 2) April 1, 2025 January 16, 2026 January 1, 2027 June 1, 2028 
Smallest Volume (Tier 3) January 1, 2026 October 18, 2026 October 1, 2027 June 1, 2028 

The 1071 rule faces intense debate in Congress. Efforts to refine or possibly repeal the rule are ongoing. We’ll keep you updated on any changes.

The Authors
Andrea J. Shaw
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Practus, LLP provides this information as a service to clients and others for educational purposes only. It should not be construed or relied on as legal advice or to create an attorney-client relationship. Readers should not act upon this information without seeking advice from professional advisers.

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