Policy Briefing — October 2, 2025
CFPB finalized its Section 1071 extension, pushing small business lending data collection to July 1, 2026, January 1, 2027, and October 1, 2027 depending on origination volume.
Executive briefing: The Consumer Financial Protection Bureau finalized the June 2025 interim rule that extended the Equal Credit Opportunity Act Section 1071 compliance tiers by roughly one year, locking in new go-lives of July 1, 2026 for Tier 1 lenders, January 1, 2027 for Tier 2, and October 1, 2027 for Tier 3, with first data submissions due the following June.1 The Bureau confirmed firms can annualize originations from 2022–2025 to determine their tier and may start test collection 12 months before the new deadlines.1
Key compliance checkpoints
- Tier verification. Recalculate covered transaction counts using 2022–2023 data or the optional 2023–2025 lookback to confirm the applicable compliance tier and filing deadline.1
- Grace period planning. Document how the 12-month early-collection allowance will be used to validate Section 1071 demographic fields, system integrations, and fair lending controls before the official go-live.1
- Litigation alignment. Track ongoing court stays noted by the CFPB so any relief for association members is incorporated into rollout plans while maintaining readiness for the nationwide dates.1
Operational priorities
- Workflow remediation. Update LOS, CRM, and disclosure workflows with the revised deadlines but keep sprint capacity allocated for demographic intake, firewall controls, and data-submission QA.
- Policy updates. Refresh ECOA/Regulation B procedures to reflect the staggered compliance dates and to show how staff training cadence matches the new milestones.
- Vendor governance. Reconfirm vendor delivery dates for Section 1071 modules or managed services to ensure contractual SLAs align with the July 2026 start for Tier 1 institutions.
Enablement moves
- Use the extra runway to pilot demographic data validation, second-line monitoring, and submission reconciliation in production-like sandboxes.
- Bundle board and executive reporting on small-business lending, fair lending risk, and Section 1071 technology spend to evidence oversight through the extended timeline.
Sources
Zeph Tech centralizes CFPB timelines, maps compliance tiers, and gives lending teams a control checklist for Section 1071 data collection.