On November 13th, the CFPB issued a revised proposal to implement the Section 1071 requirements of the Dodd-Frank Act. While there are obviously some provisions the CFPB is looking to change, other potential requirements were untouched. Here are a few of the proposed changes:
- The threshold for determining coverage is proposed to be 1,000 covered credit transactions in each of the two preceding calendar years instead of 100.
- The mandatory compliance date is proposed to be January 1, 2028, for all covered institutions. No more tiered compliance dates.
- A “small business” is proposed to be a business with gross annual revenue of $5 million or less for its preceding fiscal year instead of $1 million or less.
- It’s proposed that credit transactions for agricultural purposes be excluded from both reporting and coverage.
Jerod gave a brief synopsis of the proposal during our November Monthly Connection and also covered it in more depth during our 1071 Thought Leadership, Implementation & Planning Membership Group meeting on November 19th. Here’s a little snippet:
Published
2025/11/24
