Section 1071 Data Field Readiness Check
One question per required data point. Answer them as your loan origination system stands today, and the report at the bottom names the fields you are not collecting at all and the ones you are collecting in a form that will not survive validation.
Nothing leaves your browser. This page has no backend, no signup and no third-party service. Your answers are held in the page and turned into a report by JavaScript running on your own machine. They are never uploaded, never logged and never stored. You can confirm that in your browser’s network tab, or by disconnecting from the network and using the page anyway.
Fifteen data points, not twenty. Section 1002.107(a) is numbered to twenty, but paragraphs (3), (4), (11), (12) and (16) currently read [Reserved]. Five data points that earlier versions of the rule required — and that a good deal of published guidance still lists — are not in the operative text. This check covers the fifteen that are. See what happened to the other five.
Run the check
For each data point, pick the answer that describes your system today. Partly is the useful answer when you hold something but not in the form the rule asks for — free text where a code is required, or a value your system cannot produce for every application.
What happened to the other five data points?
Paragraphs (3), (4), (11), (12) and (16) of § 1002.107(a) read [Reserved] in the operative text as it stands at the issue date named in the methodology below. A reserved paragraph is a numbered slot the agency has emptied without renumbering the ones around it, which is why the list still counts to twenty while requiring fifteen things.
The practical consequence is worth stating plainly, because it cuts both ways. You are not required to build collection for a reserved data point. But a great deal of 1071 guidance, vendor material and internal project documentation was written against the earlier list and has not been revised, so a readiness exercise run off any of it will hand you five fields of work that the rule does not ask for. Before acting on any 1071 field list — including this one — check it against the operative text for the date you are reading it.
How to read the report
The report sorts your answers into three groups rather than giving you a score, because a score would flatten the one distinction that matters here. Not collected is a build: the field does not exist in your system and something has to be added to capture it. Collected but not reportable is usually smaller work and more urgent, because the data is already arriving and is being stored in a shape that will fail validation — free text where a code is required, a value captured for some applications and not others, or a field that exists but is not populated in practice. That second group is where filings actually come apart, and it is invisible in a gap analysis that only asks whether a field exists.
Methodology
The data points, their numbering and the reserved paragraphs are read from 12 CFR 1002.107(a) as published in the eCFR, title 12, chapter X, part 1002, subpart B, at the eCFR issue date of 28 August 2026. Nothing in the field list is our summary of what the rule ought to require; where this page quotes a requirement, it is quoting that section.
The questions are ours. The rule states what has to be compiled; it does not tell you which way an origination system usually fails to compile it. So each question tests reportability rather than mere presence, and the wording reflects where the gap tends to sit in practice rather than the structure of the regulation.
Rule text last checked: 1 September 2026. Section 1071 has moved more than once and will move again, including the reconsideration rulemaking that produced the reserved paragraphs above. If you are reading this well after that date, verify the field list against the operative text before you plan work from it. If you believe a reading here is wrong, tell us — we would rather fix it than be cited incorrectly.
Cite this page
You may republish this check with attribution and a link to https://rataassociates.com/section-1071-data-field-readiness-check/.
Plain text
RATA Associates. “Section 1071 Data Field Readiness Check.” Field list read from 12 CFR 1002.107(a), eCFR issue date 28 August 2026. Last checked 1 September 2026. https://rataassociates.com/section-1071-data-field-readiness-check/
Link
<a href="https://rataassociates.com/section-1071-data-field-readiness-check/">Section 1071 Data Field Readiness Check</a> — RATA Associates
Who built this
RATA Associates has prepared HMDA and CRA submissions for banks and credit unions continuously since 1987, and Section 1071 is the third register we have built collection and validation for. The ordering of the questions, and the note under each gap, come from that rather than from the rule: which fields origination systems actually miss, and which ones they capture in a shape that fails on the way out. The collection, validation and submission side is Comply SBL (1071); the background on the rule itself is on our Section 1071 page.
