Section 1071 Coverage Checker: Are You Covered, and From When?
Rule text last verified: August 10, 2026
Section 1071 of the Dodd-Frank Act requires lenders to collect and report data on small business credit applications. Which lenders, and from when, changed substantially on May 1, 2026, when the CFPB published a reconsideration final rule. Most guidance still online describes the previous version. This page describes the current one.
Three things changed that decide whether the rule applies to you at all. The origination threshold went from 100 covered credit transactions to 1,000. The gross annual revenue ceiling in the definition of a small business dropped from $5 million to $1 million, so fewer of your borrowers count as small businesses in the first place. And the tiered phase-in is gone, replaced by a single compliance date of January 1, 2028 for every institution that remains covered.
Check your coverage
Count only credit transactions you originated to small businesses, meaning businesses with gross annual revenue of $1 million or less. Nothing you type leaves your browser.
Who is a covered financial institution
You are a covered financial institution if you originated at least 1,000 covered credit transactions to small businesses in each of two consecutive years. Both years have to clear the threshold. One year at 1,200 and the next at 800 does not make you covered, which is why the checker asks for two figures rather than an average.
The reconsideration rule raised this from the original 100 transactions. That is a tenfold increase, and it is the single change most likely to move an institution out of scope entirely. If you built a 1071 programme against the old threshold, the first thing worth doing is re-running the count.
What counts as a small business now
A small business is one with gross annual revenue of $1,000,000 or less. The previous definition used $5,000,000. This matters twice over: it shrinks the population of applications you would have to report, and because the origination threshold counts transactions to small businesses, it also shrinks the number you count when testing whether you are covered at all. Institutions near the line should test both together rather than in sequence.
The compliance date
There is one date: January 1, 2028, and it applies to every institution that remains covered. The rule states that it "extends the compliance date to January 1, 2028, for all financial institutions that remain covered by the rule."
The tiered schedule that circulated for the past two years, with separate dates for lenders above 2,500, above 500 and above 100 originations, no longer describes the rule. Neither do the intermediate extensions issued in 2025. If a compliance calendar in your shop still carries a 2026 or 2027 date drawn from those tiers, it is out of date.
What data the rule requires
The core of the collection is unchanged in shape: application and credit details, the census tract of the principal place of business, gross annual revenue, NAICS code, and demographic information about principal owners collected directly from the applicant rather than proxied. The reconsideration rule removed several discretionary data points, specifically application method, application recipient, denial reasons, pricing information and number of workers. It also modified how business ownership status and principal owner demographics are formatted.
Because the field list moved, any mapping work done against the earlier data dictionary needs re-checking before it is relied on. Comply SBL (1071) handles the collection, the geocoding of business addresses and the NAICS validation, and our Section 1071 overview covers the requirement in more depth. For the scoping question this checker tests — the revenue definition, the transaction count, and which products are covered — see what actually counts as a small business loan under Section 1071.
If you are near the threshold
Falling below 1,000 in one of the two years takes you out of scope for that test, but it is not a reason to stop counting. Volume moves, the two-year window rolls forward, and an institution that sits between roughly 800 and 1,200 originations can cross in and out of coverage year to year. The practical answer for anyone in that band is to keep counting covered originations under the current small business definition even while out of scope, so that the year you do cross, you already know it and have two clean years of data behind you rather than a reconstruction exercise.
The same applies in reverse to institutions that geared up under the old 100-transaction threshold. Being out of scope today does not undo the work, and the collection infrastructure is what makes the next threshold test cheap.
Methodology and sources
Every figure on this page is read from the CFPB's reconsideration final rule, Small Business Lending Under the Equal Credit Opportunity Act (Regulation B), published May 1, 2026 as Federal Register document 2026-08494 and effective June 30, 2026. Read it at the Federal Register, or start from the CFPB's Section 1071 rulemaking page.
Two things this page deliberately does not state, because the rule text does not settle them: the first filing deadline for data collected on and after the compliance date, and which two specific calendar years are used to test the threshold for that date. Check the CFPB's filing instructions guide for those rather than inferring them from the old tiered schedule. This page is a reading of the rule, not legal advice, and it is not a substitute for your own counsel.
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RATA Associates, "Section 1071 Coverage Checker," rule text verified August 10, 2026. https://rataassociates.com/sbl-1071-coverage-checker/
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