Section 1071 Reset: What Financial Institutions Should Do Before 2028 

The CFPB’s May 1, 2026 final rule revised parts of Regulation B, subpart B, which implements Section 1071 of the Dodd-Frank Act for small business lending data collection. The rule amended coverage for certain financial institutions and credit transactions, changed certain data point requirements, and extended the compliance date to January 1, 2028. 

For many financial institutions, the new timeline creates a practical opportunity. Rather than waiting until 2027 to begin system changes, year-end 2026 planning can be used to assess readiness, assign ownership, and build a testing schedule that reduces pressure closer to implementation. 

Reassess Coverage and Loan Products 

The CFPB states that Section 1071 is intended to require covered financial institutions to collect and report data on applications for credit for women-owned, minority-owned, and small businesses. The reconsideration rule also amended coverage for certain credit transactions and institutions, making coverage analysis an important first step. 

• Review small business lending activity for 2026. 

• Identify which products, channels, and business units may be in scope. 

• Confirm how covered applications will be tracked from intake through final action. 

• Document assumptions used in the coverage review. 

Evaluate Loan Origination Systems 

Section 1071 compliance will depend heavily on whether loan origination systems can capture, store, and report required information consistently. Even institutions with strong lending platforms may need workflow changes, new required fields, revised user permissions, or integration updates. 

• Compare current system fields against expected Section 1071 data needs. 

• Identify data captured manually, outside the system, or in narrative notes. 

• Review vendor timelines for updates, testing, and release schedules. 

• Determine whether reporting data can be extracted in a reliable format. 

Update Procedures and Training 

The CFPB’s implementation resources identify key provisions related to definitions, coverage, data points, firewall requirements, and reporting requirements. Those areas should be reflected in policies, procedures, and staff training before data collection begins. 

• Draft or revise procedures for application intake, data collection, and quality review. 

• Build role-based training for lenders, loan assistants, compliance staff, and reviewers. 

• Address customer-facing conversations around demographic and ownership information. 

• Create escalation steps for incomplete, unclear, or inconsistent information. 

Build a 2027 Testing Timeline 

A January 1, 2028 compliance date can arrive quickly when system development, vendor coordination, training, and data testing are involved. Covered institutions that originated at least 1,000 covered credit transactions for small businesses in both 2026 and 2027 must comply beginning January 1, 2028. 

• Schedule mock application testing in 2027. 

• Test data entry, review steps, reporting extracts, and exception tracking. 

• Involve compliance, lending, IT, operations, and internal audit early. 

• Provide management and the board with periodic readiness updates. 

Use the Reset Wisely 

The extended deadline should not be treated as a pause. It is a chance to make Section 1071 readiness part of normal planning, budgeting, and governance. Brady Martz professionals can help financial institutions organize implementation planning, assess documentation needs, and prepare for clearer conversations with management and the board.