1071 Update – February 2025

The regulatory landscape surrounding Section 1071 is evolving rapidly under the new administration and ongoing legal proceedings. We will continue to provide updates as applicable, but institutions should have a proactive monitoring plan to ensure they stay informed and on track with compliance requirements.  

Here are the latest updates on Section 1071 implementation and broader Consumer Protection Bureau (CFPB) oversight: 

Table of Contents 

• What’s the status of 1071? 
• Will there be any other efforts to delay or stop 1071?
• How is Ncontracts preparing for 1071 implementation? 

What’s the status of 1071? 

Section 1071 compliance dates are paused for some small business lenders after a ruling from  the Fifth Circuit Court of Appeals  covering all plaintiffs and intervenors (Plaintiffs and Intervenors, include: Texas Bankers Association; Rio Bank, McAllen, Texas; American Bankers Association; Texas First Bank; Independent Bankers Association of Texas; Independent Community Bankers of America, Texas Farm Credit; Farm Credit Council; Capital Farm Credit, XL Funding, L.L.C.; Equipment Leasing and Finance Association; Rally Credit Union; Credit Union National Association; and Cornerstone Credit Union League). The case is ongoing. 

1071 compliance dates remain in effect for lenders that aren’t included in the plaintiff and intervenors class. These lenders should continue with 1071 preparations.  

 The compliance deadlines are: 

• Tier 1:  July 18, 2025 (filing June 1, 2026) 
• Tier 2:  Jan 16, 2026 (filing June 1, 2027) 
• Tier 3: Oct 18, 2026 (filing June 1, 2027) 

Additionally, the CFPB's newly appointed Acting Director, Russell Vought has made clear that the administration doesn't plan to continue with former CFPB Director Chopra's ultra-aggressive approach to regulation and enforcement. Given the focus of the new administration, the acting director, and the ongoing litigation, it is likely that Section 1071 will be delayed further; however, we are still awaiting formal decisions from the CFPB and the Fifth Circuit Court of Appeals.

Will there be any other efforts to delay or stop 1071? 

At least two bills to either amend or repeal Section 1071 of the Dodd-Frank Act have been introduced. These bills face a long journey through Congress – and passage isn’t a certainty. The bills’ text hasn’t been published yet.    

How is Ncontracts preparing for 1071 implementation?  

Ncontracts’ N1071 solution helps commercial lenders comply with 1071 with software and services to guide lenders and help them comply with the new requirements.  

It begins with a customizable model policy and procedure checklist created by Ncontracts experts to demonstrate how to implement 1071 from a governance and practical perspective. 

Ncontracts software will help transmit 1071 data and analyze it for disparate impact. 1071 regulatory updates, enforcement actions, and guidance are built into the system​. 

Ncontracts assists lenders in setting up software with appropriate data to reflect internal processes and provide unlimited remote training of users on system, policy, and procedures to ensure full utilization. An unlimited number of users have access to the software along with training modules with videos and knowledge checks to train business units, executives, and the compliance team on 1071.​ 

For the most up-to-date information on 1071 and other regulatory compliance issues, log into Ncomply. 

Looking for more 1071 information? Visit our 1071 Resource Page.