RoutineMetric

CFPB Section 1071 Compliance Tier & Deadline Calculator

Analyze your small business loan originations across 2023, 2024, and 2025 to determine coverage under the CFPB's Section 1071 Final Rule. Includes revised dates factoring in post-stay extensions.

Origination Profile

Required to determine if you qualify for the earliest compliance phase (Tier 1).

Total covered transactions to businesses with gross revenues ≤ $5 million.

What is a Covered Loan?

Under Section 1071, covered credit transactions include small business term loans, lines of credit, business credit cards, and merchant cash advances. Lenders must report applications from businesses with gross annual revenues of $5 million or less.

Exempt

Currently Exempt

Calculation ConfidencePending Inputs

Provide your annual loan origination volumes to compute coverage and compliance deadlines.

Data Collection StartN/A
First Filing DeadlineN/A

Required Transactional Data Points (12)

Review the core fields that covered institutions must record on small business loan applications.

Unique Application Identifierapplication

A unique alphanumeric sequence to identify the application without revealing personal info.

Application Dateapplication

The calendar date on which the institution received the covered application.

Application Methodapplication

How the application was received (e.g., in-person, online, telephone, mail).

Credit Type Requestedapplication

Specific type of credit product (e.g., term loan, line of credit, credit card, SBA loan).

Credit Purposeapplication

Primary purpose of the funding (e.g., working capital, equipment, real estate, business acquisition).

Credit Amount Applied Forpricing

The initial amount of credit requested by the applicant.

Action Taken & Dateapplication

The outcome (approved, denied, withdrawn, incomplete) and date action was taken.

Census Tract (Location)application

Geographic location indicator where the credit will be primarily applied.

Gross Annual Revenue of Businessdemographics

The gross annual revenue of the business applicant in their last fiscal year (must be <= $5M to qualify).

Business Ownership Statusdemographics

Whether the business is minority-owned, women-owned, or LGBTQI+-owned.

Demographics of Principal Ownersdemographics

Ethnicity, race, and sex of principal owners holding 25% or more equity.

Pricing Parameters & Feespricing

Origination charges, interest rate details, broker fees, and prepayment penalty terms.

Deep Dive: CFPB Section 1071 Small Business Lending Data Rule

The Consumer Financial Protection Bureau’s (CFPB) Section 1071 of the Dodd-Frank Act represents the most significant regulatory change to business lending data compliance in decades. Designed to mirror Home Mortgage Disclosure Act (HMDA) data collection, Section 1071 requires financial institutions to gather and report transaction-level data on credit applications for small businesses.

Post-Supreme Court Stay Revisions

Originally finalized in March 2023, compliance dates were temporarily stayed due to ongoing federal litigation (Texas Bankers Association v. CFPB). Following the Supreme Court's May 2024 ruling regarding the CFPB's funding structure, the Bureau adjusted the enforcement timeline by adding exactly 290 days to accommodate the duration of the judicial stay. The dates modeled in this calculator reflect the final post-stay revisions, ensuring compliance teams prepare for the true regulatory start dates.

Defining Tier Eligibility and "Covered Lenders"

A financial institution is subject to Section 1071 if it meets the definition of a "covered lender" and crosses the threshold of originating 100 or more covered credit transactions in each of the two preceding calendar years. These tiers determine your institutional launch phase:

  • Tier 1 (2,500+ originations): High-volume institutions must begin compiling records on July 18, 2025, and complete their debut electronic LAR transfer by June 1, 2026.
  • Tier 2 (500 to 2,499 originations): Mid-sized lenders must implement operational frameworks to capture metrics starting January 16, 2026, and file by June 1, 2027.
  • Tier 3 (100 to 499 originations): Community banks, Credit Unions, and local CDFIs are given until October 18, 2026, to activate reporting procedures, with their first filing cycle due June 1, 2027.

Firewall Requirements and Safe Harbors

Section 1071 contains strict demographic firewall stipulations. Loan officers evaluating an application are restricted from seeing demographic markers (race, gender, LGBTQI+ indicator status) collected for 1071 purposes unless the institution determines that the firewall is impractical to maintain. In such cases, the lender must provide specific notice to the applicants. This calculator and compliance checklist provide a roadmap to structure your systems and comply without disruption.