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Compliance tier | Original compliance date | New compliance date | First filing deadline |
Tier 1 institutions (highest volume lenders) | October 1, 2024 | July 18, 2025 | June 1, 2026 |
Tier 2 institutions (moderate volume lenders) | April 1, 2025 | January 16, 2026 | June 1. 2027 |
Tier 3 institutions (smallest volume lenders) | January 1, 2026 | October 18, 2026 | June 1, 2027 |
CFPB issues an interim final rule to implement section 1071 of the Dodd-Frank Act
The CFPB is extending compliance deadlines for the small business lending rule. After the CFPB issued this rule on March 30, 2023, some lenders filed challenges against it in federal court in Texas. On July 31, 2023, that court stayed the rule for certain lenders pending the Supreme Court’s decision in CFPB v. CFSA; on October 26, it extended that stay to all lenders covered by the rule. In the event of a reversal in CFSA, the Texas court ordered the CFPB to extend the rule’s compliance deadlines to compensate for the period stayed.
The CFPB now plans to issue an interim final rule to extend compliance deadlines. As 290 days have elapsed between the July 31 order and the CFSA decision on May 16, the interim final rule will extend compliance dates. Click here to read the CFPB’s full announcement.
The Small Business Lending Rules for Section 1071 of the Dodd-Frank Act
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Wolters Kluwer offers consulting services including data preparation and file scrubs, submission support, staff training, regulatory interpretation, operational planning, Compliance Management System (CMS) oversight, and small business Fair Lending risk reviews utilizing industry proven strategies to ensure compliance with complicated regulatory requirements.