On Nov. 13, 2025, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule (2025-19865.pdf) to amend Section 1071’s small business lending data collection requirements. The proposed changes are a substantial departure from the 1071 final rule issued in 2023 and narrows its scope and breadth. Some of the biggest changes include:

• Raising the origination threshold from 100 to 1,000 covered credit transactions for each of two consecutive years.
• Changing the gross annual revenue threshold in the rule’s definition of small business from $5 million or less to $1 million or less.
• Limiting the number of data points required to be collected by focusing data collection on data points specifically identified in Section 1071 and a limited number of other data points. Remove discretionary data points for application method, application recipient, denial reasons, pricing information and number of workers.
• Extend the compliance date to Jan. 1, 2028, for all covered financial institutions.

Doeren Mayhew’s Financial Institutions Group will continue to follow any updates issued by the CFPB on this matter and others. Need assistance with ensuring compliance with lending regulations? Rely on our regulatory compliance pros to keep your institution compliant.