In case you missed it, the CFPB just shook up the compliance calendar (again).
On June 18, 2025, the CFPB published an interim final rule that officially extends the deadlines for its 2023 small business lending rule, better known as Section 1071 of the Dodd-Frank Act. This rule requires financial institutions, including credit unions, to collect and report detailed demographic data on small business loan applicants. Sound familiar? It’s the regulation that sparked more questions than answers over the last two years.
So, what’s changing, and what does your credit union need to do now to avoid a compliance scramble down the road?
Let’s break it down.
Legal challenges to the original rule have been bouncing through multiple courtrooms across the country. Due to the ongoing litigation, courts issued stays that temporarily paused the compliance deadlines for some lenders.
Rather than leave everyone hanging in limbo, the CFPB extended the compliance timelines by roughly one year for all covered institutions and clarified how these changes apply across the board. The goal? Level the playing field and reduce confusion.
And in a twist, the Bureau also hinted that it plans to revisit the rule entirely — but more on that in a bit.
Here’s how the new dates shake out:
| Tier | Lending Volume | New Compliance Date | First Filing Deadline |
| Tier 1 | High | July 1, 2026 | June 1, 2027 |
| Tier 2 | Moderate | January 1, 2027 | June 1, 2028 |
| Tier 3 | Low | October 1, 2027 | June 1, 2028 |
You can determine your tier based on small business loan originations during any of the following rolling 2-year windows:
Even though the timeline just got pushed out, this isn’t a “set it and forget it” moment. In fact, now is the perfect time to get ahead.
Here’s what your credit union should focus on now:
One thing that didn’t budge: the filing deadline. Regardless of your tier, your data must be submitted to the CFPB by June 1 of the year following your data collection period.
So, for Tier 1 lenders with a July 1, 2026 start, you’ll still be looking at June 1, 2027 to file your first round of data.
For credit unions, this extension is both a relief and a reminder.
Yes, you have more time, but the expectations haven’t gone away. And with the added uncertainty of potential rule changes in the near future, it’s smart to treat this time as a gift, not a delay.
The good news? You don’t have to figure it out alone.
At Comply-YES!, we’ve helped credit unions of all sizes tackle Section 1071 planning with practical, actionable strategies. From identifying your tier and testing your data workflows to preparing policies and conducting staff training—we’re here to make compliance a whole lot less chaotic.
Some ways we can support you:
Looking for one-time guidance? We’ve got you. Need a long-term partner to keep you on track? We’re ready when you are.
The CFPB’s latest move gives credit unions a chance to catch their breath, but don’t wait until the 11th hour to act. Start laying the groundwork now, build strong workflows, and lean on your trusted partners to keep your team ahead of the curve.
Want to talk through how this update impacts your institution? We’d love to hear from you.
Reach out to the Comply-YES! team today.
And if you’re still wrapping your head around what Section 1071 means in the long run, you’re not alone. We’re keeping tabs on the CFPB’s next move and will be ready with more insights as things evolve.
