Section 1071 Delay Insights
As we reported back in June, the CFPB published an Interim Final Rule that officially delayed the Section 1071 dates as follows:
Tier 1 - July 1, 2026
Tier 2 - January 1, 2027
Tier 3 - October 1, 2027
Essentially, this kicks the can down the road for now so that the CFPB has some time to rewrite the regulation. They also need to issue a proposal, allow time for a comment period and then issue a final rule, which we believe will delay things beyond these revised dates. Jerod gave some insight to this during the June meeting of our 1071 Thought Leadership, Implementation & Planning Membership Group.
He also shared some thoughts on all the work and preparations made up to this point. Not all is lost. There is still value in what you’ve done, and it can still be utilized in the meantime to improve your commercial lending procedures and processes.
Published
2025/07/18
Jerod Moyer
Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!