1071 Update: July 2025

The regulatory landscape surrounding Section 1071 continues to evolve amid 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? 

In early 2025, Section 1071 litigation was still unfolding. Now we have more clarity from the CFPB, though more changes — and potential delays — may be on the way.

In June, the CFPB released an interim final rule extending the compliance dates previously established in the 2023 final rule and later amended by the 2024 interim final rule. The dates apply to everyone regardless of stay status.

The new compliance deadlines are:

• Tier 1: July 1, 2026 (filing June 1, 2027)
• Tier 2: Jan 1, 2027 (filing June 1, 2028)
• Tier 3: Oct 1, 2027 (filing June 1, 2028)

The CFPB is updating its grace period policy to reflect the new dates and is seeking public comments by July 18, 2025, the rule’s effective date.

In April, the CFPB officially deprioritized enforcement and supervision actions for entities outside the stay imposed under Texas Bankers Association v. CFPB No. 24-40705 (CA5), leveling the playing field for all lenders. Since the Fifth Circuit Court of Appeals granted Texas Bankers’ appeal request in February, the pause on the rule only applies to lenders named in the case. Most lenders still aren’t required to comply as the case continues.

The CFPB has also indicated its intentions to issue a new rule, which means the current rule may undergo significant changes. Lenders should continue to monitor updates and stay connected to their Ncomply solution.

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

Two bills to either repeal or amend Section 1071 of the Dodd-Frank Act were introduced in February. The first, the 1071 Repeal to Protect Small Business Lending Act (H.R.976), aims to repeal the requirement for financial institutions to collect and report demographic and application data on women-owned, minority-owned, and small business loan applications. The other, the Small LENDER Act (H.R.941), doesn’t eliminate or modify the underlying data requirements themselves. Instead, it suggests a three-year transition and two-year enforcement grace period for qualifying small-business lenders to adapt and comply.

How is Ncontracts preparing for 1071 implementation?  

Ncontracts is closely monitoring updates to 1071 and publishing them in our compliance management software, Ncomply. Log in regularly so you don’t miss the latest updates and information on 1071 compliance.

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 starts 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 potential issues. 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 the 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.​

As the CFPB releases updates, our innovation team will continue to adapt our tools to keep you compliant and prepared.

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