CFPB updates small business lending instructions

The Consumer Financial Protection Bureau updated its 2025 Small Business Lending Filing Instructions Guide.

Details: The 2025 updates include:

• Changing the applicable filing period to reflect the 1071 rule’s updated Tier 1 compliance dates of July 18, 2025, through Dec. 31, 2025.

• Changing the Action Taken Date & Application Date data point examples so that they reflect the new compliance dates.

• Modifying the validation ID E0321 to reflect the updated filing period based on the new Tier 1 compliance dates.

Previous Announcements: The CFPB recently released a revised Small Entity Compliance Guide with the 1071 rule’s revised compliance dates. The bureau in June issued an interim final rule extending the compliance deadlines following a Supreme Court ruling that ended a temporary injunction on the 1071 rule.

Ongoing Court Challenge: In a statement following the court decision, ICBA said it continues to look forward to judicial review of the CFPB’s 1071 rule. A court filing from ICBA, the Independent Bankers Association of Texas, and Texas First Bank argues that the CFPB violated the law in issuing its 1071 rule by exceeding its statutory authority and by failing to comply with the Administrative Procedures Act when it finalized the rule.

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