The Section 1071 Final Rule released on May 1, 2026, culminated a strange and chaotic road. We’ve been saying since the beginning that 1071 wasn’t going away; it was just a matter of what it would look like in the end. While many institutions will now be outside the coverage of 1071, that relief may not last forever. Section 1071 coverage will be based on an ongoing loan volume test and, in the Final Rule, the CFPB signaled the possibility of expanding 1071 coverage in the future. This all means that being out today doesn’t necessarily mean you will be out forever. While we don’t anticipate 1071 coverage being expanded for some time, it’s important your Board of Directors understands that 1071 coverage isn’t a “one and done” test.
Jerod explains more in the video.
Published 2026/06/19