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.
