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All in Regulation B
In this Compliance Clip, Adam provides a high-level overview of the CFPB’s November 2025 proposed revisions to the Section 1071 small business data collection rule. While the proposal signals a significant shift from the March 2023 final rule, key details remain unsettled and could have meaningful implications for financial institutions. Watch the video as Adam briefly discusses what’s changing, what’s still uncertain, and why these proposed revisions deserve close attention.
On November 13, 2025, the CFPB issued proposed revisions to certain provisions of Regulation B, subpart B, implementing changes to the Equal Credit Opportunity Act made by section 1071 of the Dodd-Frank Act. The CFPB believes the proposed changes would streamline the rule, reduce complexity for lenders, and improve data quality, advancing the purposes of section 1071 and complying with recent executive directives.
On November 13, 2025, the CFPB issued a proposed rule that amends provisions related to disparate impact, discouragement of applicants or prospective applicants, and special purpose credit programs under Regulation B, the regulation implementing the Equal Credit Opportunity Act (ECOA). According to the CFPB, the amendments would facilitate compliance with ECOA by clarifying the obligations imposed by the statute.
On October 2, 2025, the CFPB issued a final rule to finalize its June 18 interim final rule amending Regulation B to extend the compliance dates of the small business lending rule and to make other date-related conforming adjustments. This final rule becomes effective on December 1, 2025.
On July 25, 2025, the Ballard Spahr reported that a number of community groups filed a complaint with the U.S. District Court for the District of Columbia against Acting CFPB Director Russell Vought and the CFPB seeking to force the agency to implement the section 1071 rule. The community groups that filed the lawsuit include Rise Economy, fka California Reinvestment Coalition (Rise), the National Reinvestment Coalition (NCRC), the Main Street Alliance (MSA) and Reshonda Young.
In this Compliance Clip (video), Adam breaks down the requirements in Regulation B as to when a borrower must get a copy of the appraisal used in their loan. Not only is the timeframe for delivering the appraisal discussed, Adam also covers when the appraisal delivery requirements of Regulation B apply. A transcript of this video is now available.
On April 30, 2025, the CFPB announced that it will not prioritize enforcement or supervision actions with regard to Section 1071 Rule to entities that are currently outside the stay imposed under Texas Bankers Association v. CFPB lawsuit. According to the CFPB, it will instead keep its enforcement and supervision resources focused on pressing threats to consumers, particularly servicemen and veterans.
In this Compliance Clip (video), Adam discusses the nuances of adverse action notices in the context of declined counteroffers for commercial loans. He explains the regulatory framework under Regulation B and the implications for lenders when an applicant withdraws their application after a counteroffer is declined.
On January 17, 2025, the CFPB took action against Draper & Kramer Mortgage Corporation for discriminatory mortgage lending activities that discouraged homebuyers from applying to Draper for homes in majority-Black and Hispanic neighborhoods in the greater Chicago and Boston areas. CFPB Director Rohit Chopra said that the Bureau’s proposed order bans Draper from mortgage lending for five years and ensures that the company pays for its unlawful discrimination.
In this Compliance Clip (video), Adam answers a question about who can fill out the 1071 data collection form when there are multiple principal owners of a business opening an account. I other words, can one principal owner answer the demographic questions on behalf of the other principal owners, or do they each need to answer their own questions?
