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New 1071 Small Business Data Collection and Submission Proposed Rule: What Does It Mean and What Has Changed?

After many fits and starts, whether from the courts, the new administration, or the CFPB itself, we finally have a new proposal to work with. The good news is many of the asks the industry has had with the CFPB have been answered, and in a good way. There’s a significant chance this proposal will be finalized the way it’s written, so it’s time to parse the requirements and figure out what we have to do.
Upcoming
Monday, December 1st, 2025
10:00 am - 12:00 pm
Presented by Carl Pry
$299.00 or 1 Token

Includes: Live Access, 30 Days OnDemand Playback, Presenter Materials and Handouts

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From changes in reporting thresholds and new exemptions to revised definitions of “small business loan” and revised data elements to report, there’s still a lot to do. The good news here is it looks like collection won’t be required until 2028 for everyone (no tiers anymore), but that’s not that far away. There’s also good news in that much of the implementation work small business lenders did in anticipation of the new rule won’t go to waste – we just have to revise what we have to do.
In this webinar we’ll go in-depth into the new proposal and nail down precisely what you have to do, when you have to do it, and in what format. But our focus will not be a simple recitation of the proposed rule, but how to effectively develop/refine your implementation plan. We’ll review the many issues so you can methodically ensure your program is on track.
We’ll also talk about what this data means from a fair lending standpoint, including the (eventual) public nature of the information and some suggestions for fair lending analytics, as well as policy and procedure impacts. Join us for this in-depth discussion of the rule so you can best prepare for implementation, both operationally and technologically, and also culturally. Use this extra time before finalization and implementation of the new rule to make sure things are right.

What You'll Learn

  • Side-by-side comparison of what the new proposal contains against the previous version of the final rule – what changed and what stayed the same?
  • Who is covered? Examining the coverage thresholds and new timing requirements
  • Interplay between this rule, HMDA, and CRA reporting requirements
  • Who is a “covered financial institution”?
  • Determining what to report – covered credit transactions and covered originations
  • What types of applications will be reported? How is an application defined for this purpose?
  • Deep dive into the data points – both those generated by the lender as well as those provided by the applicant, including data elements no longer part of required collection
  • Collecting demographic information – forms, verifications, policies, procedures, and (fortunately) no responsibility to guess: less than beforens
  • The “firewall” requirement – ensuring lenders to not have improper access to the data
  • Safe harbor and “bona fide errors” provisions
  • Likelihood of finalization

Who Should Attend

This session is designed for anyone who needs to understand the updates and revisions of the CFPB’s proposed rule. It will be particularly beneficial for compliance officers, as well as those working in commercial lending, compliance, training, loan services, auditing, and senior management.
Carl Pry

Instructor Bio


Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Senior Advisor for Asurity Advisors in Washington, DC. Through his more than 35-year working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves as the Chair of the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.


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