December 2, 2025

On October 2, 2025, the Consumer Financial Protection Bureau (“CFPB”) finalized a rule amending Regulation B to extend compliance deadlines for its Section 1071 small business lending data collection requirements under the Dodd-Frank Act. For context, Section 1071 is part of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (defined above as the “Dodd-Frank Act”) and directs the CFPB to collect data on small-business lending activity to create a transparent and standardized record of how credit is being extended to small businesses nationwide.

The extension moves most first filing deadlines into 2026 and 2027 and gives lenders additional time to build reporting systems for demographic and loan-level data. The CFPB explained that this adjustment provides operational relief while preserving the rule’s purpose of improving transparency in small business credit. For lenders, servicers, and compliance teams, the delay may offer time to strengthen data-collection workflows and technology systems before enforcement resumes.

Importantly, the final rule is effective as of December 1, 2025, and the rule’s structure remains unchanged. Covered lenders must still collect information on small business loan applications including, but not limited to, demographic data, credit outcomes, and application details, to help monitor fair lending practices. Larger institutions will begin collecting data first and then smaller lenders in later phases will follow suit. The Bureau stated that this timeline aligns with recent court orders delaying enforcement but reaffirmed that all covered entities will eventually need to comply. Institutions engaged in commercial or mixed-purpose real estate loans should review their origination procedures now to ensure readiness when reporting begins.