Letter to the CFPB on the 1071 Final Rule

Dear Kris, 

I am writing to share with you some frequently asked questions about the 1071 final rule. I hope that the Bureau will consider addressing these questions as it updates implementation materials that were issued after the Bureau published the final 1071 rule in 2023. I would be happy to discuss any of these questions with you. 

1. Timing of the filing instructions guide (FIG) and other implementation materials. The CFPB has not shared when the updated FIG and other implementation guides will be published. For the FIG in particular, it would be extremely helpful to have an approximate target, e.g., the last quarter of 2026, the first quarter of 2027, etc. Covered institutions have myriad other responsibilities besides 1071 that require IT resources; not knowing even approximately when the FIG will be published makes it impossible to appropriately plan for and use IT resources in an efficient manner, particularly at the end of a calendar year when banks are generating year-end reports for regulatory and business reasons. Banks are reluctant to begin work using the 2023 FIG, both because of changes made by the 2026 final rule and concern that, even for data points that were not revised in the 2026 rule, the revised FIG may be different than the 2023 FIG.  

Download the letter to read the full text.