Section 1071: Why 2027 Is the Real Deadline for Small Business Lenders

The CFPB's May 2026 Section 1071 final rule narrowed small business lending data collection to approximately 13 required fields and raised the reporting threshold to 1,000 covered originations. Many institutions have read the narrowed rule as a reason to slow down, but collection systems must be operational before January 1, 2027, a full year before data collection begins, and that window is closing. This session explains what changed in the final rule, how institutions can confirm whether they are still required to report, and which elements of earlier Section 1071 build work to preserve, modify, or retire. Attendees will leave with a practical roadmap for reaching operational readiness by 2027 and the internal business case to fund it.  

Discussion Topics

• Confirm whether their institution remains a covered financial institution under the final rule's 1,000-loan threshold before committing budget to a build or rebuild. 
• Identify the approximately 13 required data fields, recognize what the final rule removed, and determine which existing collection processes to preserve. 
• Build an implementation timeline that treats January 1, 2027 as the operational deadline and accounts for the cost of a late start. 
• Present a fact-based case to senior management and the board for beginning, or resuming, Section 1071 preparation now.  

Speakers