The Section 1071 Final Rule defines a “covered financial institution” as …a financial institution, other than a Farm Credit System lender, that originated at least 1,000 covered credit transactions for small businesses in each of the two preceding calendar years. This is a significant increase (from what had been 100 covered credit transactions) and will likely eliminate many financial institutions from coverage. That said, when you set out to determine whether your institution is covered, there is a special transitional rule that you could, but are not required to, utilize.
Compliance with the Final Rule is mandatory on January 1, 2028.
Jerod explains more in the video.
Published 2026/06/15