Our June 1071 Membership Group meeting focused on counting covered credit transactions to determine financial institution coverage.
In short, an institution will be subject to the 1071 data collection and reporting requirements if it originated at least 1,000 covered credit transactions to small businesses in each of the prior two calendar years. To determine coverage for purposes of the January 1, 2028, mandatory compliance date, institutions can look to their origination volume in either 2025 and 2026 or in 2026 and 2027.
Institutions need to know what’s included and excluded from this count and understand that determining 1071 coverage is not a “one and done” exercise. Institutions that are not subject to 1071 initially could become subject to the requirements in the future. Thus, institutions need to think through how they are going to document whether they are “in” or “out”.
Hear what Jerod had to say about documenting the process:
Published 2027/07/16