For Section 1071, a …covered application means an oral or written request for a covered credit transaction that is made in accordance with procedures used by a financial institution for the type of credit requested. If this sounds familiar, it’s because the CFPB kept in line with Regulation B’s existing definition of an application. However, the CFPB did not adopt Regulation B’s definition of a “completed application” with respect to Section 1071, as explained within the section-by-section analysis of the Final Rule:
The Bureau is also not adopting existing Regulation B’s definition of a “completed application,” as urged by some commenters. Although the Bureau agrees that a “completed application” definition would provide greater uniformity, the definition would exclude incomplete applications and most withdrawn applications.
Jerod explains this more in the video, as well as which applications are in and out.
Published 2026/07/02