Extension of 1071 SBL Compliance Dates

On June 18 2025, the CFPB issued an interim final rule to extend the compliance dates set in the 2023 final rule, as previously amended by a 2024 interim final rule, by approximately one year. This extension applies to all financial institutions required to collect and report data on small business credit applications. The revised compliance dates are as follows:

• Highest Volume Lenders (Tier 1): The new compliance date is July 1, 2026, with the first filing deadline on June 1, 2027. (Original compliance date: October 1, 2024; Revised 2024 interim final rule date: July 18, 2025).
• Moderate Volume Lenders (Tier 2): The new compliance date is January 1, 2027, with the first filing deadline on June 1, 2028. (Original compliance date: April 1, 2025; Revised 2024 interim final rule date: January 16, 2026).
• Smallest Volume Lenders (Tier 3): The new compliance date is October 1, 2027, with the first filing deadline on June 1, 2028. (Original compliance date: January 1, 2026; Revised 2024 interim final rule date: October 18, 2026).

Financial institutions can determine their compliance tier by using their small business originations from either 2022 and 2023; 2023 and 2024; or 2024 and 2025.

Reasons for the 1071 SBL Extension

The primary reason for this extension is ongoing litigation and court orders challenging the 2023 final rule. While some court orders had stayed compliance deadlines for specific plaintiffs and intervenors, the compliance dates remained unchanged for other financial institutions. By extending the dates for all lenders, the CFPB aims to ensure a consistent and orderly implementation process across the industry.

Additionally, the extension provides the CFPB with time to initiate new SBL rulemaking. The Bureau intends to issue a notice of proposed rulemaking as expeditiously as reasonably possible to reconsider certain aspects of the 2023 final rule.

This extension reflects the CFPB's response to legal challenges and its commitment to ensuring a more effective and equitable implementation of SBL data collection requirements.

What Institutions Should Do Now to Prepare

With the compliance landscape for the Small Business Lending (SBL) rule continuing to evolve, financial institutions face the challenge of adapting to extended deadlines while preparing for potential future revisions. Proactive engagement and strategic internal readiness are key to navigating these changes effectively. Here are four ways institutions can position themselves now for successful future compliance:

1. Provide Your Feedback. The public comment period offers a crucial opportunity for financial institutions to provide direct feedback to the CFPB regarding the interim final rule and the broader implications of the SBL rule. It's essential to not only state your position, but also to provide specific, data-backed insights into operational challenges, compliance costs, and potential unintended consequences of the rule's current structure. This input can significantly influence the shape of the upcoming new SBL rulemaking. As always, follow your organization’s requirements for submitting public comments on behalf of your institution. Also, consider collaborating with industry associations or legal counsel to ensure your comments are impactful and aligned with broader industry perspectives. This is your chance to help shape a workable and effective regulation that helps your institution succeed while meeting its regulatory requirements. 

2. Inform Your Organization. Given the fluctuating nature of the SBL rule compliance landscape, continuous and clear communication across your organization is paramount. Beyond informing leadership, establish a robust internal communication plan to keep all affected departments—including legal, compliance, IT, lending operations, marketing, and training—fully abreast of the latest developments. Regular updates, internal FAQs, and dedicated training sessions can help manage expectations and prevent missteps. Emphasize why these changes are occurring (e.g. ongoing litigation, CFPB's intent to refine the rule) to foster understanding and buy-in, rather than just relaying dates. A well-informed organization where all stakeholders are kept up to date is critical to fulfilling the requirements for a new regulatory initiative.

3. Plan for Change. Despite the extensions and the anticipation of new rulemaking, the core mandate of SBL rule—to collect and report SBL data—remains. Therefore, institutions should continue to strategize and build foundational capabilities that will be essential regardless of specific data fields. Focus on establishing robust data governance frameworks, enhancing data accuracy, and developing flexible IT systems capable of adapting to potential changes in reporting requirements. Proactive planning should include reviewing current loan origination systems (LOS) and customer relationship management (CRM) platforms to assess their adaptability for new data points. Consider consolidating and streamlining lending processes now to improve overall operational efficiency, which will be beneficial regardless of the final rule's specifics. By focusing on fundamental data management and process improvements, institutions can reduce future compliance burdens and ensure they are well-positioned when the final, stable version of the rule takes effect.

4. Build Training Frameworks. Now is the right time to ensure that robust processes are in place to provide colleagues with the training they will need to effectively implement this rule when the time comes. While the specific details of the next rule are yet to be finalized, institutions can leverage these extended compliance dates to build the foundational training framework. This involves identifying key impacted roles, developing flexible training content on core concepts that will remain constant, and establishing an effective learning management system. A proactive approach to training now will ensure staff are well-prepared and can adapt quickly when the final version of the SBL rule is eventually implemented.

No Time to Waste

As the landscape for the Small Business Lending (SBL) rule continues to evolve, the extended compliance dates offer a critical window that institutions cannot afford to waste. Despite the ongoing litigation and the CFPB's intent to propose new rulemaking, the core mandate of Section 1071—to collect and report SBL data—remains firm. This period of adjustment is not a time to be idle , but is rather a strategic opportunity. By actively providing feedback, ensuring thorough organizational awareness, proactively planning for process and system changes, and preparing comprehensive training programs, financial institutions can transform uncertainty into a pathway for smoother, more effective, and ultimately, compliant implementation of this regulation. Use this extra time to prepare your legacy systems for the data extraction, assess  any software you may need to help with your SBL submission, and evaluate the staffing and training needs that come with a new regulation.

By Sarah Brons

Sarah Brons is Product Leader, CRA & 1071 SBL Products for RiskExec, Inc. Sarah brings in-depth community development and CRA compliance expertise developed through experience in bank examining, bank CRA program development, and industry engagement.

Sarah joined RiskExec from American Express where she served in the American Express National Bank Center for Community Development as Director leading the CRA Grant and Service Programs. She previously held Community Development Officer and CRA Officer positions in two other large banks.

Prior to joining her roles in banks, Sarah served as a bank examiner with the Office of the Comptroller of the Currency where her responsibilities included conducting CRA exams for banks of all sizes. Sarah earned her BSBA from the University of Nebraska at Omaha.