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ARTICLE · 26 NOVEMBER 2025

Section 1071 Rule Proposed Amendments—A Deeper Dive

Ballard Spahr LLP
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As previously reported, the CFPB is proposing major changes to its 2023 final rule that would require financial institutions to report information contained...

United StatesConsumer Protection
Richard J. Andreano, Jr.
Richard J. Andreano, Jr.
John L. Culhane, Jr.
John L. Culhane, Jr.
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As previously reported, the CFPB is proposing major changes to its 2023 final rule that would require financial institutions to report information contained in loan applications submitted by small businesses, including women-owned and minority-owned small businesses. The rule is better known as the "Section 1071 rule" after the section of the Dodd-Frank Act that required the CFPB to adopt it. Comments must be received by December 15, 2025.

The proposed amendments would reduce the number of financial institutions subject to the rule, the transactions that are covered by the rule, and the data points that must be collected and reported under the rule. Reflecting its overall approach to the proposed revisions, the CFPB states in the preamble to the proposal that it "preliminarily believes that [the] reaction to the 2023 final rule, practically speaking, was in part based on its expansive approach, appearing to seek broad coverage of lenders, products, and information

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