CFPB’s Section 1071 “Reconsideration” Creates a Two-Track Reality: Build Now, Design for Change
Section 1071 is now a two-track implementation: tiered compliance dates beginning July 1, 2026 remain the planning baseline while CFPB reopens core design inputs in a reconsideration NPRM—raising late-stage change and version-control risk.
CFPB is advancing Section 1071 on two tracks: published tiered compliance dates remain the current planning baseline, while a reconsideration NPRM reopens coverage, definitions, and required data points (and potentially the schedule). The build challenge is meeting near-term deadlines while engineering for change.
What you need to know
The move: CFPB issued a Nov. 13, 2025 reconsideration proposed rule that would revise certain provisions of Regulation B, subpart B, implementing Section 1071. (Consumer Financial Protection Bureau)
Why it matters: The Bureau is reconsidering core elements—coverage, definitions, how certain data points are collected/included, and the compliance date—which raises the likelihood of late-stage design adjustments even as implementation work proceeds. (Consumer Financial Protection Bureau)
Who should care: Small business lending product and operations leaders, fair lending and model risk teams, CIO/data platform owners, and vendor management teams supporting LOS/CRM/reporting systems.
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