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SBL 1071

What Actually Counts as a Small Business Loan Under Section 1071

August 10, 2026 RATA Associates 5 min read
What Actually Counts as a Small Business Loan Under Section 1071

A financial institution is a covered institution under Section 1071 if it originated at least 1,000 covered credit transactions to small businesses in each of the last two calendar years, where a small business is one with gross annual revenue of $1 million or less. Both numbers changed on May 1, 2026, when the CFPB published a reconsideration final rule that raised the origination threshold from 100 and lowered the revenue ceiling from $5 million. If your institution is testing scope against the older figures, the test is wrong, not just outdated. The rule's definition of a small business, and where the revenue threshold sits Section 1071 of the Dodd-Frank Act only counts credit extended to a "small business," and the definition is entirely about gross annual revenue: $1 million or…

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Section 1071 in 2026: What Lenders Need to Know About Small Business Lending Data

January 31, 2026 RATA Associates 6 min read
Section 1071 in 2026: What Lenders Need to Know About Small Business Lending Data

Section 1071 of the Dodd-Frank Act represents the most significant expansion of lending data collection requirements since HMDA. As 2026 unfolds, more financial institutions are entering the compliance timeline, making this an important moment to understand what's required and how to prepare. This guide covers the current state of Section 1071 implementation, who needs to comply and when, and practical steps for building your compliance infrastructure. What Is Section 1071? Section 1071 requires financial institutions to collect and report data on small business lending applications. The goal mirrors HMDA's purpose for mortgage lending: to identify potential discrimination and ensure fair access to credit for minority-owned, women-owned, and other small businesses. The Consumer…

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