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.
Under the final rule, the new compliance dates will be as follows:
Highest volume lenders (Tier 1)
New compliance date: July 1, 2026
New first filing deadline: June 1, 2027
Moderate volume lenders (Tier 2)
New compliance date: January 1, 2027
New first filing deadline: June 1, 2028
Smallest volume lenders (Tier 3)
New compliance date: October 1, 2027
New first filing deadline: June 1, 2028
Covered financial institutions are permitted to continue using their small business originations from 2022 and 2023 to determine their compliance tier, or they may instead use their originations from 2023 and 2024, or from 2024 and 2025. Covered financial institutions are permitted to begin collecting protected demographic data required under the 2023 final rule 12 months before their new compliance date, in order to test their procedures and systems.
The final rule can be found here.
