The mandatory compliance date for the Section 1071 Final Rule is January 1, 2028. While this may not seem like a lot of time in compliance time, we’ve known a lot about what these requirements would look like since at least March of 2023. While it’s taken longer than expected and there have been changes along the way, the CFPB assumes that covered institutions have been working on their 1071 framework and implementation plan all along. We hope so too! The Final Rule allows (but does not require) financial institutions to “practice” their complete data collection efforts 12 months prior to the mandatory compliance date (1-1-2027), which will be here before you know it.
Regardless of where you are at with your implementation plan, make sure you keep your Board in the know!
Jerod explains more in the video.
Published 2026/07/06