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HMDA, CRA and Section 1071 are three separate federal reporting regimes. HMDA (Regulation C) covers applications for dwelling-secured loans. CRA data reporting covers small business, small farm and community development loans at banks above the small bank size. Section 1071 (Regulation B, subpart B) will cover small business credit applications at lenders that originate at least 1,000 a year for two years running. They overlap more than their names suggest. All three hang on a census tract, two of them ask about demographics, and one loan can look like it belongs on two registers when the rules put it on only one. Below, the three sit side by side. Every threshold and date below comes from the current regulation text or the agency notice that set it, and the sources are listed at the…

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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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