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