Every Required Data Point, Three Tabs
Section 1071 asks about the application, the business and the people who own it. Each has a home.
The fields are the regulation, in the order the regulation asks
Section 1071 is not a longer HMDA record; it is a different one. Rather than bolt small-business fields onto a mortgage screen, the SBLAR tabs mirror the CFPB’s own structure — so what a reviewer asks about is where you would expect to find it.
- Legal Entity Identifier and Unique ID validated on entry, not at export.
- NAICS code and flag captured per application, with the not-provided codes the spec requires.
- Amount applied for and amount originated kept separate, as the rule distinguishes them.
Pricing is the part that becomes a fair lending question
The 2026 reconsideration rule dropped pricing information from the required 1071 collection — but it did not stop a regulator comparing origination charges, broker fees, annual charges, rate type, margin and prepayment terms across borrower groups. Those comparisons happen under ECOA whether or not the field is on the SBLAR. Collected as structured fields they can be analysed before someone else does it; collected in a spreadsheet, or not at all, they cannot.
- Business profile workers, time in business, ownership status and number of principal owners.
- Credit product, guarantee and purpose with the “other” free text the spec pairs with each.
- Full pricing block fixed and variable rate detail, fees, and prepayment penalty flags.
Four owners, five race codes each, and proxies for the blanks
Demographics you have never had to collect, from up to four principal owners per business, many of whom will decline to answer. The derived BISG proxy fields sit beside the reported ones, so the analysis you run later has something to work with where the applicant left it blank.
- Up to four principal owners across two tabs, each with multi-select ethnicity and race.
- BISG race, ethnicity and sex proxies derived and stored alongside the reported values.
- Feeds Comply Fair Lending directly — the same database, so nothing is re-keyed to analyse it.
- 39years, since 1987
- Hundredsof institutions filing
- 2028single compliance date
- 4principal owners per business
Why Section 1071 Is Harder Than HMDA
If you already file HMDA the mechanics will feel familiar. The data will not.
Multiple principal owners
Race, ethnicity and sex for up to four owners per business, each with an ownership stake — where HMDA asks about one applicant and one co-applicant.
Business-level data
Revenue, NAICS code, time in business and business type. None of it has an equivalent on a mortgage record.
Application-level detail
Credit purpose, credit terms, additional guarantors and pre-qualification status, captured per application — alongside the discretionary fields the 2026 rule dropped, for institutions that keep collecting them anyway.
Rules still moving
Section 1071 edit checks continue to evolve. Comply SBL updates automatically with each CFPB clarification, the same way its HMDA edits have since 1987.
Tier 1 now, everyone after
Whether you are already reporting or waiting on your compliance date under the phased timeline, the collection work starts before the deadline rather than at it.
Built on what already files your HMDA
Microsoft .NET and SQL Server — the same architecture hundreds of institutions have submitted HMDA from for over 39 years. Not a new vendor to onboard.
Key Features of Comply SBL (1071)
Data import and collection
The Import Wizard reads fixed-length and delimited files from your origination system, with flexible field mapping and custom conversions so data meets CFPB requirements on the way in, not after.
Comprehensive edit checking
Every CFPB-mandated validity and quality edit for Section 1071, updated automatically as the CFPB refines the specification. Mark quality edits verified to streamline review across cycles.
Application and owner data management
Multiple owners per application, with demographics, ownership percentages and every Section 1071 data point tracked. Application View for one record, List View for batch editing.
Geocoding integration
RATA's Compliance-grade geocoding is built in: batch the whole dataset or geocode one application instantly, with re-geocoding handled automatically when an address changes.
Filtering and reporting
Filter by any combination of application, demographic or geographic criteria and save the definition for reuse. Generate standard or custom reports, or export for outside analysis.
Submission preparation
The Submission Wizard validates that data is edit-free and fully geocoded, then generates the file in exact CFPB format — so the upload to the government portal holds no surprises.
Benefits of Choosing Comply SBL (1071)
Built on proven technology
The architecture, interface and workflow come from the same Comply platform hundreds of institutions already use for HMDA, CRA and Fair Lending — not a new product built from scratch.
Regular updates
As the CFPB refines Section 1071 requirements and edit specifications, the software updates automatically. No manual monitoring of the regulation required on your end.
Expert support
RATA's compliance experts know both the technical and regulatory sides of small business lending data, and are available throughout implementation and every reporting cycle.
Scalable solution
Dozens of small business loans a year or thousands — the same SQL Server architecture supports multiple concurrent users and large datasets either way.
Frequently Asked Questions
The four we are asked most often about Section 1071, answered properly rather than in a sentence. If yours is not here, it is a better use of your time to ask a person.
Ask us directlyWhat is Section 1071 small business lending data collection?
Section 1071 of the Dodd-Frank Act requires financial institutions to collect and report data on small business loan applications. This includes information about the business (gross annual revenue, NAICS code, time in business), ownership demographics (race, ethnicity, sex of principal owners), loan terms, and credit decisions. The CFPB uses this data to enforce fair lending laws and promote small business credit access.
When do I need to start reporting SBL 1071 data?
There is a single compliance date of 1 January 2028 for every institution that remains covered. The tiered phase-in that set separate dates for lenders above 2,500, above 500 and above 100 originations was replaced by the CFPB reconsideration final rule of 1 May 2026, so the earlier asset-tier and volume-tier timelines no longer apply. That rule also raised the coverage threshold to 1,000 covered credit transactions to small businesses in each of the two preceding calendar years, and lowered the small business definition to $1 million in gross annual revenue, so many institutions that geared up under the old 100-transaction threshold are no longer covered at all. Comply SBL is ready for the 1 January 2028 date.
Counting to that threshold is its own question, since a covered credit transaction is not simply any loan to a small business: we go through which originations actually count as small business loans before you re-run the count.
What data points are required for Section 1071 reporting?
Required data includes application date, loan amount, loan type, loan purpose, credit decision, business NAICS code, gross annual revenue, time in business, census tract (via geocoding), and demographic information for up to 4 principal owners (race, ethnicity, sex), collected directly from the applicant rather than proxied. The CFPB's reconsideration final rule of May 1, 2026 removed the discretionary data points for application method, application recipient, denial reasons, pricing information and number of workers — so any field mapping built against the earlier data dictionary needs re-checking. Comply SBL manages the required fields with built-in validation, and still captures the discretionary ones for institutions that choose to keep collecting them.
Does Section 1071 require geocoding like HMDA?
Yes, Section 1071 requires census tract geocoding for each covered application. Comply SBL includes integrated Compliance-grade™ geocoding with 95%+ accuracy. Batch geocode your entire dataset or geocode individual applications instantly. Our geocoding service uses Census Bureau TIGER data and handles address standardization, matching, and census tract assignment automatically.
Comply SBL Software vs Manual Collection
See how Comply simplifies Section 1071 compliance
| Compliance Task | With Comply SBL | Manual Process |
|---|---|---|
| Data Collection | Structured application-level data entry with validation rules. Tracks every required data point including business demographics, principal owner information, and loan characteristics. | Spreadsheet tracking prone to errors. Missing data fields discovered late. Difficult to ensure data completeness across every required element. |
| Owner Demographics | Systematic collection of principal owner race, ethnicity, sex, and veteran status. Automated calculation of minority-owned, women-owned, and LGBTQI+-owned business status based on ownership percentages. | Manual tracking of ownership percentages. Complex calculations for majority ownership determination. High risk of classification errors. |
| Geocoding | Integrated Compliance-grade™ geocoding with 95%+ accuracy. Batch processing for entire dataset with Census Bureau TIGER data. | Manual census tract lookup for each business address. Time-consuming, error-prone. May not meet CFPB accuracy standards. |
| NAICS Code Assignment | Built-in NAICS code lookup and validation. Ensures 6-digit codes match Census Bureau classifications. | Manual NAICS code research. Difficult to stay current with code changes. Classification errors common. |
| Phase Compliance Tracking | Automatically tracks which phase requirements apply based on your institution's lending volume. Ensures data collection matches CFPB timeline. | Manual tracking of three-phase implementation requirements. Risk of collecting insufficient or excessive data. |
| Validation Rules | Built-in CFPB validation edits. Identifies missing data, invalid codes, and logical inconsistencies before submission. | Errors discovered after CFPB submission rejects file. Resubmission delays, potential compliance violations. |
| Submission File Generation | One-click creation of CFPB submission file in required format. Pre-validated, submission-ready output. | Manual file formatting to CFPB specifications. Format errors lead to submission failures. |
| Time to Prepare Submission | Days from data collection to CFPB-ready file | Weeks or months of manual preparation |
What Our Customers Say
Trusted by financial institutions nationwide for compliance excellence
“The folks at RATA were outstanding. Every time I had a question, I would speak to someone who either knew the answer immediately or could provide the answer within a very short period of time. Everyone I spoke with knew their product, industry and was willing to do whatever it took to help us solve our problem. I would highly recommend RATA and COMPLY to anyone who is considering this company and product.”
“The support has been exceptional. The program is very easy to use. RATA has been one of the best companies I have dealt with in my 25 years of banking. Their service has exceeded my expectations.”
“I wanted to let you know that RATA and Comply is the absolute best!!! My submission is complete and was accomplished in record time. I more than doubled the amount of activity I reported last year and it took me less than half the time. Thank you for being there for us and the industry! You are and always will be number one to me!!!”
… and hundreds of others since 1987
