Letter to CFPB on the Interim Final re: Small Business Lending

Re: Small Business Lending Under the Equal Credit Opportunity Act (Regulation B); Extension of Compliance Dates, Docket No. CFPB–2025–0017; RIN 3170–AB40

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Dear Acting Director Vought,

The American Bankers Association (ABA) appreciates the opportunity to comment on the CFPB's section 1071 interim final rule published on June 18, 2025 (IFR). We support the IFR's extension of the mandatory compliance dates for 1071 compliance. ABA is also pleased that the CFPB plans to revise the 1071 rule published on May 31, 2023 (2023 Final Rule). The 2023 Final Rule is unduly burdensome and will increase costs for small businesses seeking credit. In this letter we offer comments on the IFR and some suggestions for the CFPB's consideration as it drafts amendments to the 2023 Final Rule.

Comments on the Interim Final rule

In April 2023, the ABA, the Texas Bankers Association and other trade associations challenged the CFPB's 1071 rule in federal court in Texas. After the district court ruled for the CFPB, the ABA and other trade associations filed an appeal in the 5th Circuit Court of Appeals and in February 2025, the 5th Circuit stayed and ordered tolling of the rule's compliance date pending the appeal. Although the stay and tolling order is in place for our members, ABA supports extension of the mandatory compliance dates for approximately one year. Extending the compliance dates via the IFR should provide more certainty for all lenders and for vendors that are integral to 1071 compliance.

We appreciate the Bureau's decision to set the three compliance dates on the first day of a calendar quarter. This should make the transition to collecting data smoother and should improve data analysis. The IFR also is helpful in confirming that, under § 1002.114(c), lenders may collect demographic information beginning 12 months before their mandatory compliance dates.

Download the comment letter to read the full text.

Letter to CFPB on the Interim Final re: Small Business Lending

Comments on the Interim Final rule

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Letter to CFPB on the Interim Final re: Small Business Lending

Comments on the Interim Final rule

In Depth

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