This post was updated to reflect new compliance deadlines finalized by the CFPB on May 1, 2026.
New timelines for small business loan data collection and reporting
The Consumer Financial Protection Bureau (CFPB) in 2026 issued a final 1071 rule that extends the section 1071 compliance date for all covered financial institutions to Jan. 1, 2028. The new rule for collecting data on small business loan activities replaces a 2023 rule framework and its tiered implementation deadlines.
You might also like this one-page PDF with key dates and details on complying with the 1071 rule.
Takeaway 1
The effective date of the CFPB's new rule based on Section 1071 of the Dodd-Frank Act is June 30, 2026, and the compliance deadline is Jan. 1, 2028. The initial reporting deadline is June 1, 2029.
Takeaway 2
To implement the 1071 requirements, covered financial institutions should begin by understanding the rule and determining their volume of small business loan originations in either 2026 and 2027 or 2025 and 2026.
Takeaway 3
The 2026 final rule excludes several types of small business credit. But the CFPB left the door open to future expansions of data requirements based on its learnings from initial 1071 reporting.
Final rule
Effective dates & compliance dates for rule 1071
As they do with any new requirement, financial institutions want to know when the CFPB 1071 rule is effective and when they must begin collecting and reporting data on their small business lending activities.
The effective date of the Consumer Financial Protection Bureau’s (CFPB) new rule was August 29, 2023.
However, the CFPB recently finalized later deadlines for compliance and reporting the data collected about small business loan applications. With an initial compliance due date of Jan. 1, 2028, for all covered financial institutions, lenders with higher volumes of originations should begin preparing now.
The CFPB’s small business data collection rule implementing Dodd-Frank 1071 has gone through many iterations in recent years. Court cases and changes to the rule have delayed compliance dates numerous times, in much the same way compliance with the current expected credit loss (CECL) model was delayed by several actions.
In the case of 1071, the CFPB in 2025 undertook a comprehensive review of the rule and finalized its changes on May 1, 2026, so financial institutions now have a clearer picture of deadlines and requirements.
Lenders should continue to monitor ongoing regulatory and legislative efforts to revise collection and reporting deadlines and requirements. But for now, the new 1071 compliance and reporting deadlines are as follows:
| Type of 1071 deadline | Deadline |
|---|---|
| Data collection efforts must begin | January 1, 2028 |
| Report data to CFPB | June 1, 2029 |
Source: CFPB
How to stay ahead of compliance
Despite the seemingly long runway to prepare, it's not too early to get a handle on the new requirements and how they will affect a bank or credit union. With the changes, many financial institutions face the most significant data collection and reporting effort in nearly 50 years. Given this scope, lenders need to begin assessing now how and when they will comply.
In addition, the CFPB has made it clear it may expand 1071 reporting requirements over time, so smaller-volume lenders will want to monitor 1071 rule developments. The final rule described that the bureau is taking an incremental approach to “better serve the statutory purposes of section 1071 in the long term.” It said:
“Such an approach will start with core lending products, core providers, and core data points….Over time, as the Bureau and financial institutions learn from early iterations of data collections, the Bureau could consider amending the rule.”
Abrigo has helped thousands of bank and credit union staff members learn more about 1071 and how to prepare for it through educational webinars, podcasts, and whitepapers. The company, which provides lending and compliance solutions to more than 2,400 financial institutions, has 1071 lender resources to help financial institutions capture small business loan data, store it, and report it to the CFPB to comply with the required timelines.
CFPB 1071 resources include Abrigo's small business loan origination software for automating 1071 data collection and reporting. It has built-in data firewalls and permissioning features that allow covered financial institutions to collect the required data and file it with the CFPB in compliance with the new rule. Abrigo's 1071 reporting capabilities mean banks and credit unions can collect all required data fields in a borrower-facing form, access pre-built reports, and easily enforce firewall requirements to limit access to 1071 personal data.
Below are important details on 1071 compliance, including which financial institutions must comply, what the changes involve, and important 1071 compliance dates.
Fair lending regulations
What are the goals of 1071?
Before discussing 1071 compliance dates and detailed requirements, it’s helpful to understand the rule’s goals and which financial institutions it affects.
The final rule implements section 1071 of the Dodd-Frank Act by amending the Equal Credit Opportunity Act (ECOA), or Regulation B (Reg B). The CFPB small business lending data collection regulations are being included as subpart B of Reg B and aim to support and enforce the fair lending requirements. CFPB intends the data collected by lenders on each small business credit application to facilitate enforcement of fair lending laws, especially those related to minority-owned and women-owned small businesses. Reporting on the data is also expected to help creditors, communities, and governmental entities identify small business owners’ needs and credit opportunities.
While the 2023 final rule for small business lending data collection meant lenders would have to collect more than 80 pieces of data per application, the 2026 final rule has streamlined collection and reporting. This final rule removes the discretionary data points for application method, denial reasons, pricing information, and number of workers from the prior rule's requirements. It also narrows the reporting categories for race, ethnicity, and sex of principal owners, and eliminates the need to determine LGBTQ+ ownership status.
Covered lenders & credit types
Which lenders are "covered financial institutions" in the 1071 rule?
The rule outlines that any company or organization engaged in lending activities may be covered by the requirements. Farm Credit System lenders and motor vehicle dealers are excluded, but banks, credit unions, savings associations, online lenders, commercial finance companies, non-profit lenders, and government lenders are among those that will need to determine whether they meet the origination threshold for compliance.
To be subject to the rule’s requirements at all (i.e., to be considered a “covered financial institution”), a company or organization must have originated at least 1,000 covered credit transactions in each of the preceding two calendar years.
Institutions can use origination counts from either 2026 and 2027 or from 2025 and 2026 for the initial determination of whether it is a covered financial institution. Institutions that aren’t covered initially are required to begin tracking and reporting the small business lending data once they meet the threshold of 1,000 covered originations in two preceding calendar years.
What is a covered transaction
The CFPB generally describes it as a request for any of the following:
- loans
- lines of credit
- credit cards
One change from the 2023 rule is that the 2026 final rule excludes from the list of covered transactions the following:
- merchant cash advances (MCAs)
- agricultural lending
- loans of $1,000 or less.
That $1,000 threshhold will be adjusted for inflation every five years.
For purposes of determining whether a financial institution is covered by the rule, requests for additional credit on an existing loan are not counted as originations. They are, however, covered transactions as they relate to tracking data for small business loan applications by covered financial institutions.
Defining "application" for a covered transaction
For data collection and reporting, financial institutions must track applications they receive for covered transactions, as opposed to solely tracking originations. What is an application under the CFPB 1071 rule? It is an oral or written request for a covered credit transaction that is made following the procedures used by a financial institution for the type of credit requested. This means that lenders must track data not only related to approved and booked credit but also applications that are for more than $1,000 in credit and are any of the following:
- withdrawn
- incomplete
- denied
- approved by the lender but not accepted by the applicant
Would you like to stay up to date on CFPB 1071 implementation?
A re-evaluation, extension, or renewal request on an existing business account is excluded from the definition of covered applications as long as the request seeks no additional credit. Inquiries and prequalification requests are also excluded.
Excluded small business credit types
Which credit transactions are excluded from 1071?
As noted earlier, in addition to loans under $1,000, the final rule excludes merchant cash advances and agricultural lending from the list of reportable transactions. Other types of transactions excluded from the CFPB’s requirements to report on applications include:
- trade credit
- public utilities credit
- securities credit
- incidental credit
- insurance-premium financing
- factoring
- leases
- consumer-designated credit used for business/ag purposes, such as taking out a home equity line of credit or charging business expenses on their personal credit cards
- purchases of originated covered credit transactions
- applications with potential HMDA and section 1071 overlap: CFPB does not require reporting under section 1071 (transactions would only be reportable under HMDA)
A final component of the rule that is useful in understanding the various deadlines for 1071 reporting is the CFPB’s description of what constitutes a small business. An applicant or borrower is considered a small business if it had $1 million or less in gross annual revenue for its preceding fiscal year before applying. That threshold was lowered from the earlier rule framework’s definition of $5 million in annual revenue.
Abrigo can help you navigate 1071 deadlines and compliance. In addition to our 1071 resource page for lenders, which has updated information to help prepare for the new requirements, Abrigo’s Loan Origination Software already has all required data fields in a borrower-facing collection form, access to pre-built reports, and the ability to export for CFPB reporting. Your financial institution can comply with 1071 while streamlining the origination process and ongoing customer management by working with a trusted partner of 2,400 institutions. Talk to a specialist to learn more.
Implement 1071 with confidence and control. Abrigo Advisory Services can help.
Abrigo Advisory
Most problem loans do not become problems overnight. Warning signs often appear months or even years before a credit deteriorates, but they are easy to dismiss when performance still appears acceptable or when annual reviews become routine.
This webinar will explore why lenders and credit teams often miss early signs of deterioration. We will discuss practical ways to strengthen ongoing monitoring, revisit original underwriting assumptions, and identify small changes before they become larger credit problems.
You will learn:
- Why delayed risk recognition remains a common credit weakness
- How covenant fatigue, small red flags, and routine annual reviews can cause lenders to overlook meaningful signals
- Why original underwriting assumptions should be tested throughout the life of the loan
View the entire webinar series here.
Some of the most important credit risks never appear directly on a financial statement. Management quality, business strategy, customer concentration, succession planning, and organizational resilience can all determine whether a borrower performs as expected or begins to deteriorate.
This webinar will examine the qualitative mistakes lenders often make when assessing borrowers. We will discuss how to evaluate the people, strategy, and operating risks behind the numbers, and why strong financial results can sometimes mask deeper vulnerabilities.
You will learn:
- Why experience does not always equal management competence
- How relationship bias, key-person dependencies, and succession risks can weaken borrower assessment
- How customer, vendor, guarantor, and revenue concentration can affect repayment risk
View the entire webinar series here.
Financial statements are the foundation of credit analysis, but they do not always tell the full story. Reported earnings, ratios, projections, and management adjustments can create a sense of confidence that is not supported by the borrower’s actual cash flow, liquidity, or financial flexibility.
This webinar will explore common financial analysis mistakes that lead lenders to misread credit risk. We will discuss how to look beyond surface-level performance, challenge assumptions, and identify warning signs that may be hidden inside the numbers.
You will learn:
- Why earnings do not always translate into repayment capacity
- How liquidity, cash flow, and working capital issues can be missed
- When management adjustments, projections, and ratios deserve closer scrutiny
View the entire webinar series here.
What if your next loan review could be faster, more consistent, and more insightful without adding hours to your team’s workload? Join Abrigo and two financial institution leaders, Hannah Primes of Seacoast Bank and Sam Patton of Old National Bank, for a practical conversation on how they use Abrigo’s AI-powered Loan Review Assistant to strengthen review processes and get more value from every review.
In this webinar, Hannah and Sam will share real-world examples of how AI is helping their teams improve workflows, enhance review effectiveness, and increase consistency across reviews. They will discuss what has worked, lessons learned, and how thoughtful prompting can help loan review teams uncover meaningful insights faster while maintaining accuracy and confidence.
You will learn:
- How Seacoast Bank and Old National Bank are using Abrigo’s AI-powered Loan Review Assistant in their workflows
- Practical ways to maximize the value of AI during the review process
- Tips for building successful prompts that generate more accurate and useful outputs
- How AI can help save time while improving consistency across reviews
- Ways to enhance review effectiveness
- What real institutions have learned from implementing AI in loan review
Asset size
$1.6 billion
Product
Abrigo Fraud Detection
Financial institution type
Credit union
Utilities Employees Credit Union (UECU), a virtual credit union serving utility workers across all 50 states, faced a growing challenge familiar to many financial institutions: how to proactively combat increasingly sophisticated fraud with limited resources.
Using Abrigo’s Fraud Detection solution, the credit union improved:
- Operational efficiency
- Collaboration between AML and fraud teams
- Detection of fraud before losses occured
The challenge: Building a proactive fraud prevention program
As a largely virtual institution with members across the country, Utilities Employees Credit Union has fewer in-person interactions than traditional financial institutions and a broader risk profile. Jennifer Poloski, Risk and Compliance Manager, oversees both fraud prevention and Bank Secrecy Act (BSA) compliance with a small team. While the credit union had invested in compliance technology, it historically lacked the data needed to fully understand the scope and nature of fraud occurring within the organization.
Like many institutions, UECU also faced internal challenges when advocating for investments in fraud technology. Demonstrating the value of proactive fraud prevention required showing leadership how investments today could help avoid significant losses tomorrow. The institution needed better visibility into fraud trends, stronger monitoring capabilities, and tools that could adapt to its unique risk profile as a nationwide, virtual credit union.
““When I came in, we weren’t quantifying fraud and we weren’t tracking it,” Poloski said. “You can’t build an effective fraud prevention program without understanding what fraud is occurring and what controls you have in place to prevent it.”
Jennifer Poloski, Risk and Compliance Manager, UECU
The solution: From fraud visibility to real-time detection
UECU began its fraud modernization journey by implementing Abrigo’s BAM+ platform, giving the institution a centralized way to monitor fraud activity, track losses, and evaluate the effectiveness of fraud controls. The platform provided critical insight into previously unmeasured fraud patterns, enabling the team to shift from a reactive to a more proactive fraud strategy.
The result: Stronger fraud prevention and operational confidence
Even before completing its Abrigo Fraud Detection implementation, UECU has already gained visibility into fraud activity and strengthened its controls. They now measure success based on fraud prevented rather than fraud losses incurred.
UECU’s fraud prevention efforts currently target 90% year-over-year fraud prevention, a goal the organization recently exceeded through a combination of technology, monitoring, and layered controls. Abrigo’s monitoring tools have also helped uncover activity extending beyond traditional fraud losses. In one notable case, an alert identified unauthorized ACH activity that ultimately led to a suspicious activity report (SAR) and contributed to a broader criminal investigation.
As Abrigo Fraud Detection comes online, UECU expects to strengthen its ability to identify suspicious activity in real time, reduce losses, and adapt to evolving fraud threats.
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Artificial intelligence is becoming a priority across financial institutions, with growing pressure from boards and leadership teams to move from exploration to implementation. While the industry continues to highlight AI’s potential, the real challenge is operational. Financial institutions are not struggling to find use cases. They are struggling to determine which ones they can confidently implement and stand behind in a regulated environment.
This session focuses on how community banks and credit unions are actually approaching AI adoption today, where implementation is gaining traction, and why some initiatives move forward while others stall. We will examine how institutions are evaluating AI through the lens of explainability, governance, and risk, and what that means for day-to-day decision-making in lending, fraud, and compliance.
You will learn:
- Where AI is delivering practical value today and why some use cases move forward while others stall
- A clear framework for evaluating AI based on explainability, control, and defensibility
- Practical steps to move from experimentation to real implementation without increasing risk
- Understanding of the AI Readiness Assessment
NCUA exams continue to follow a risk-based approach. This guide helps credit union leaders understand the NCUA’s 2026 priorities and prepare for the questions examiners are most likely to ask. It highlights key areas of focus across balance sheet management, operational risk, and compliance so leadership teams can assess readiness before their next exam.
Download the full resource to strengthen exam preparation, support board oversight, and better understand how examiners evaluate risk management practices across your institution.
You will learn:
- How examiners review credit risk, liquidity, interest rate risk, ACL practices, earnings, and capital
- What questions to expect about fraud prevention, payment systems, vendor management, cybersecurity, and operational controls
- How to prepare for AML/CFT reviews and demonstrate effective board and management oversight
Nontraditional credit pathways are the new competition
While credit unions continue to post solid lending results, a growing share of borrowing activity is occurring outside credit union channels. Younger consumers are actively using credit, but they are increasingly choosing nontraditional pathways to access it. As a result, institutions may need to look beyond funded loan volume to understand whether they are capturing future borrowers.
Consumer lending still looks strong on paper
Credit unions continue to report healthy lending performance across several core measures. According to recent NCUA data, federally insured credit unions have continued to grow loans, assets, and membership while maintaining relatively stable credit performance. For many institutions, these results reinforce confidence that consumer lending remains healthy and resilient.
Those numbers primarily measure activity that has already reached the institution. They do not show how many consumers considered borrowing but chose another provider. They do not reveal which financing decisions occurred before a member ever visited a credit union website. And they do not capture borrowing activity that happens through channels outside the traditional application process.
In other words, traditional lending metrics can only tell us what entered the funnel, not what bypassed it.
See the benefits of embracing innovation.
Customer success storiesYounger borrowers are active but borrowing differently
Research from TransUnion shows Gen Z consumers are becoming credit active earlier and at higher rates than previous generations at similar ages. At the same time, the Consumer Financial Protection Bureau has documented the rapid growth of Buy Now, Pay Later financing and other point-of-sale credit options. Taken together, these trends suggest that younger consumers are not avoiding borrowing, but are increasingly encountering credit in new places.
A consumer shopping online may be offered financing at checkout. A large purchase may come with installment-payment options embedded directly into the buying experience. In many cases, the financing decision is made before the consumer actively shops for a loan. This creates a challenge for credit unions.
Historically, lenders competed when a borrower decided they needed credit. Today, that decision often occurs within a retail, digital, or fintech environment where the credit union may never be considered.
Relationships still matter, but they require time
The growth of alternative lending channels does not necessarily mean younger consumers no longer value financial guidance. Many borrowers still seek trusted advice when making major financial decisions, comparing financing options, or evaluating the long-term impact of borrowing. That has long been one of the credit union movement's strengths.
As borrowing channels become more fragmented, that strength may become even more important. While adopting digital lending can be a draw for younger members, credit unions are unlikely to out-fintech every fintech or outspend every digital lender. What they can offer is a combination of trusted relationships, financial guidance, and personalized service that many alternative lenders cannot easily replicate.
Automating can help free up lenders
Many lenders continue to spend significant portions of their day gathering documents, tracking down information, managing workflows, and completing other administrative tasks. But every hour spent on manual processes is an hour not spent engaging members, answering questions, or identifying borrowing needs before those needs are met elsewhere.
Investing in the right technology can help free lenders from routine administrative work, allowing them to spend more time on business development and customer relationships.
For credit unions seeking to engage younger consumer lending borrowers, lending efficiency can create capacity for the conversations and guidance that strengthen member relationships.
Get curious about new generations of members
Current lending performance is supported in part by long-established member relationships. Many credit unions continue to benefit from strong member engagement, with members maintaining borrowing relationships for years or decades. These consumers are often more likely to return to familiar institutions when financing needs arise. If younger consumers increasingly encounter credit through alternative channels, credit unions may need to find ways to engage them earlier in the borrowing journey. This starts with asking a different set of questions:- Where are members borrowing when they do not come to us?
- What percentage of borrowing decisions never enter our application funnel?
- Are lenders spending enough time building relationships before borrowing needs arise?
- How would we know if younger consumer lending borrowers were disengaging before loan volume begins to decline?
This blog was developed with the assistance of ChatGPT, an AI large language model. It was reviewed and revised by Abrigo's subject-matter expert for accuracy and additional insight.
You might also like this NCUA exam preparation guide
Get the guideFAQ
Why should credit unions be concerned about borrowing activity outside their institution?
Borrowing activity that occurs outside the credit union may signal changing consumer preferences and decision-making habits. If members increasingly choose financing options offered through retailers, fintechs, or digital platforms, credit unions may have fewer opportunities to build lending relationships that can lead to future products and services.
Why are younger consumers using alternative credit options?
Younger consumers increasingly encounter credit at the point of sale through Buy Now, Pay Later programs, embedded financing offers, and digital lending platforms. These options are often integrated directly into the purchasing experience, making them convenient and immediately accessible. While traditional loans remain important, many younger borrowers are exploring multiple credit channels depending on the purchase and situation.
Does strong loan growth mean a credit union is successfully reaching younger borrowers?
Not necessarily. Loan growth is an important measure of performance, but it only captures activity that reaches the institution's lending funnel. A credit union can experience healthy loan growth while still missing opportunities to engage younger consumers who are obtaining credit through alternative providers before ever considering a traditional loan application.
How can credit unions strengthen relationships with younger borrowers?
Building relationships with younger borrowers often starts before a loan application is submitted. Financial education, personalized guidance, proactive outreach, and convenient lending experiences can help credit unions remain relevant throughout the borrowing journey. Establishing trust early may increase the likelihood that consumers consider the credit union when future financing needs arise.
What role does lending automation play in member engagement?
Lending automation can help reduce the time lenders spend on administrative and manual tasks. By streamlining workflows, gathering information more efficiently, and accelerating decision-making, credit unions can create more capacity for lenders to focus on member conversations, financial guidance, and relationship-building activities that differentiate the institution from many alternative lending providers.
