The Consumer Financial Protection Bureau’s new compliance deadlines for its Section 1071 small-business data collection rule will help avoid confusion and unnecessary burden and ensure that data are collected consistently across financial institutions, the American Bankers Association said today in a letter to the bureau. At the same time, ABA suggested the CFPB provide answers to several questions regarding the implementation of the rule as banks prepare for compliance.
The CFPB in May pushed back the implementation dates for the rule. The new compliance deadline for Tier 1 institutions is July 18, 2025, with the first filing deadline on June 1, 2026. The compliance deadline for Tier 2 institutions is Jan. 16, 2026, with the first filing deadline June 1, 2027. The compliance deadline for Tier 3 institutions is Oct. 18, 2026, with the first filing deadline also June 1, 2027.
In its letter, ABA made several recommendations to provide banks more certainty as they move to meet the new deadlines. For example, ABA recommended that mandatory compliance dates should be adjusted to the first day of the month following the dates the bureau published. “These minor adjustments will help institutions transition to data collection on the first day of a calendar month,” the association said.
ABA also urged allowing early collection of demographic information, extending the grace period to the end of the calendar year and more coordination with other banking agencies in implementing the rule.
In addition, ABA also requested the CFPB provide written clarification to multiple questions on topics such as the definitions of covered small businesses and principal owners. “Clear expectations will result in less burden on institutions and more consistent and useful data,” ABA said.
