1071 reporting deadlines

Prompt

DeepSeekDeepSeek

1071 reporting deadlines

Of course. "1071 reporting deadlines" refer to the new requirements under Section 1071 of the Dodd-Frank Act, which mandates that financial institutions collect and report data about their small business lending.

The deadlines are complex because they are staggered based on the volume of a lender's small business loans.

Here is a clear breakdown of the key deadlines and what they mean.

Key Summary of Deadlines

The compliance dates are based on how many "covered originations" a lender made in each of the two preceding calendar years. A "covered origination" is generally a closed-end loan or line of credit to a small business.

Lender Tier (by # of Covered Originations)	Compliance Date (Deadline to Start Data Collection)	First Data Reporting Deadline
Tier 1: 2,500+ loans in both 2022 & 2023	October 1, 2024	June 1, 2026 (for data from Oct 1, 2024 - Dec 31, 2025)
Tier 2: 500+ loans in both 2022 & 2023	April 1, 2025	June 1, 2026 (for data from Apr 1, 2025 - Dec 31, 2025)
Tier 3: 100+ loans in both 2022 & 2023	January 1, 2026	June 1, 2027 (for data from Jan 1, 2026 - Dec 31, 2026)

Detailed Explanation of Each Deadline

There are two main types of deadlines to understand: when you start collecting data and when you start reporting it.

1. Data Collection Start Date

This is the date by which your institution must have its systems and processes in place to begin recording the required data points for every covered application.

Tier 1 (Major Lenders): October 1, 2024

You are in this tier if you originated at least 2,500 covered small business loans in both 2022 and 2023.

Tier 2 (Medium Lenders): April 1, 2025

You are in this tier if you originated at least 500 (but fewer than 2,500) covered small business loans in both 2022 and 2023.

Tier 3 (Smaller Lenders): January 1, 2026

You are in this tier if you originated at least 100 (but fewer than 500) covered small business loans in both 2022 and 2023.

Important Note: Lenders that originated fewer than 100 covered originations in both of the two preceding calendar years are exempt from these rules.

2. Data Reporting Deadline

This is the date by which you must submit your collected data to the Consumer Financial Protection Bureau (CFPB).

The reporting is done annually, by June 1 of the following year.

The first reporting deadline for all lenders is June 1, 2026.

Tier 1 lenders will report data collected from October 1, 2024, to December 31, 2025.

Tier 2 lenders will report data collected from April 1, 2025, to December 31, 2025.

Tier 3 lenders begin reporting on June 1, 2027, for their full 2026 calendar year data.

What Data Needs to Be Collected and Reported?

The rule requires the collection of a wide range of data points for each application, including:

Application Details: Date, type, amount, action taken (approved/denied), etc.

Loan Details: Credit pricing (interest rate, total costs), guarantees, etc.

Demographic Information: The race, ethnicity, and sex of the business's principal owners. This is a critical and new requirement.

Business Details: Industry, number of employees, annual revenue.

Census Tract: The location of the business.

Why is This Happening?

The goal of Section 1071 is to:

Identify business and community development needs for women-owned, minority-owned, and small businesses.

Facilitate enforcement of fair lending laws.

Enable communities, lenders, and policymakers to better understand the market for small business credit.

Action Steps for Lenders

Determine Your Tier: Immediately assess your number of "covered originations" for 2022 and 2023 to know your compliance date.

Update Systems: Begin modifying your loan origination systems, application forms, and procedures to capture all required data points.

Develop Procedures: Create a compliant process for collecting demographic data from applicants.

Train Staff: Ensure all staff involved in the lending process are trained on the new requirements.

Plan for Reporting: Develop the internal capability to compile and submit the data to the CFPB by the annual June 1 deadline.

For the most authoritative information, always refer to the official CFPB Rule and Resources:
CFPB Section 1071 Rule Implementation Page

Disclaimer: I am an AI assistant and this information is for general guidance only. It is not legal advice. You should consult with qualified legal and compliance professionals to understand how these deadlines and rules apply to your specific institution.

13:33

GeminiGoogle

1071 reporting deadlines

Okay, let's break down the reporting deadlines related to Section 1071 of the Dodd-Frank Act, which mandates the collection and reporting of small business lending data.

Key Dates to Remember:

**Compliance Date (When you must start collecting data):** This is the crucial date. You need to have systems and processes in place to accurately gather the required information from applicants.

The compliance date is tiered based on the number of covered transactions originated by the financial institution in each of the two preceding calendar years:

Tier 1 (Most Institutions): Institutions that originated at least 100 covered small business credit applications in both 2022 and 2023 must comply with Section 1071 starting October 1, 2024.

Tier 2: Institutions that originated at least 50 covered small business credit applications, but fewer than 100, in both 2022 and 2023 must comply starting April 1, 2025.

Tier 3: Institutions that originated fewer than 50 covered small business credit applications in both 2022 and 2023 must comply starting January 1, 2026.

**Reporting Deadline (When you must submit the data):** This is when you actually submit the collected data to the CFPB.

The data must be submitted annually, by June 1st of the following year. For example:

For data collected from October 1, 2024 to December 31, 2024 (for Tier 1), and then for the full year of 2025, the first reporting deadline is June 1, 2026.

For data collected from April 1, 2025, to December 31, 2025 (for Tier 2), and then for the full year of 2026, the first reporting deadline is June 1, 2027.

For data collected from January 1, 2026 to December 31, 2026 (for Tier 3), the first reporting deadline is June 1, 2027.

In summary:

Determine your Tier: Count the number of covered small business credit applications your institution originated in both 2022 and 2023. This will determine your compliance date.

Start Collecting Data: Be ready to collect the required data from every covered application on or after your compliance date.

Submit Annually: Report the collected data to the CFPB by June 1st of the following calendar year, beginning with the data collected in the partial or full calendar year that includes your compliance date.

Important Considerations:

"Covered Application": This refers to an application for credit primarily for small business purposes, as defined by the regulation. Understanding the definition of a "small business" and what constitutes a "credit application" is critical.

Data Points: Section 1071 requires collecting a significant amount of data, including information about the applicant (e.g., demographics, revenue) and the loan terms. Make sure you understand all the data points that you need to collect.

CFPB Resources: The CFPB has released extensive resources, including the final rule, interpretive guidance, and small entity compliance guides. Refer to the CFPB's website (www.consumerfinance.gov) for the most up-to-date information.

Good Faith Efforts: There are rules about obtaining demographic information from applicants. You need to make "good faith efforts" to collect this information, but you cannot deny a loan if the applicant refuses to provide it. You will need to document your efforts.

Privacy: The CFPB has rules about how you must protect the privacy of applicants, particularly regarding the collection and use of demographic information.

Amendments and Updates: Regulations can change. Stay informed about any amendments or updates to the Section 1071 rule. The CFPB's website is the best source for this information.

Consult with Counsel: Given the complexity of the regulation, it's highly recommended that you consult with legal counsel to ensure full compliance.

Example Scenario:

Let's say "Acme Bank" originated 75 covered small business credit applications in 2022 and 80 in 2023.

Acme Bank falls into Tier 2.

Their compliance date is April 1, 2025. They must begin collecting 1071 data on all covered applications received on or after this date.

Their first reporting period will be from April 1, 2025, to December 31, 2025, and then the full year of 2026.

Acme Bank's first reporting deadline is June 1, 2027.

Recommendations:

Start planning now! Even if your compliance date is further out, don't wait. The implementation process can be complex and time-consuming.

Review the CFPB's resources thoroughly.

Identify the systems and processes you need to put in place. This includes training staff, updating your loan origination system, and establishing procedures for data collection and reporting.

Consider using technology solutions designed to help with 1071 compliance.

I hope this detailed explanation helps! Let me know if you have any other questions.

13:33

MistralMistral AI

1071 reporting deadlines

Reporting deadlines can vary widely depending on the type of report, the organization, and the regulatory requirements. Here are some common reporting deadlines for various types of reports:

Financial Reporting

Annual Reports:

Public Companies: Typically due within 60-90 days after the fiscal year-end.

Private Companies: Varies, but often within 90-120 days after the fiscal year-end.

Quarterly Reports:

Public Companies: Usually due within 40-45 days after the end of the quarter.

Form 10-K (Annual Report):

Large Accelerated Filers: 60 days after the fiscal year-end.

Accelerated Filers: 75 days after the fiscal year-end.

Non-Accelerated Filers: 90 days after the fiscal year-end.

Form 10-Q (Quarterly Report):

Large Accelerated Filers: 40 days after the end of the quarter.

Accelerated Filers: 40 days after the end of the quarter.

Non-Accelerated Filers: 45 days after the end of the quarter.

Tax Reporting

Corporate Tax Returns:

Form 1120: Typically due by the 15th day of the 4th month after the end of the tax year (e.g., April 15 for calendar-year filers).

Individual Tax Returns:

Form 1040: Typically due by April 15.

Partnership Tax Returns:

Form 1065: Typically due by the 15th day of the 3rd month after the end of the tax year (e.g., March 15 for calendar-year filers).

Regulatory Reporting

SEC Filings:

Form 8-K: Due within 4 business days of the triggering event.

Form 4: Due within 2 business days of the transaction.

Environmental Reporting:

Toxic Release Inventory (TRI): Due by July 1 of each year.

Greenhouse Gas Reporting: Due by March 31 of each year.

Internal Reporting

Monthly Financial Statements:

Typically due within 5-10 business days after the end of the month.

Budget Reports:

Varies, but often due within 10-15 business days after the end of the period.

Compliance Reporting

Sarbanes-Oxley (SOX) Compliance:

Section 404: Annual assessment of internal controls due with the annual report.

Health and Safety Reports:

OSHA 300A: Due by February 1 of each year.

Other Reporting

Non-Profit Organizations:

Form 990: Typically due by the 15th day of the 5th month after the end of the tax year (e.g., May 15 for calendar-year filers).

Employee Benefit Plans:

Form 5500: Due by the last day of the 7th month after the plan year ends (e.g., July 31 for calendar-year plans).

International Reporting

IFRS (International Financial Reporting Standards):

Varies by country and specific regulatory requirements.

EU GDPR Compliance:

Data breach notification: Within 72 hours of becoming aware of the breach.

These deadlines are general guidelines and can vary based on specific circumstances, jurisdictions, and regulatory changes. Always consult the relevant regulatory bodies or professional advisors for the most accurate and up-to-date information.

13:33

Analysis

This comparison demonstrates the different approaches each AI model takes when responding to the same prompt. Here are the key differences observed:

Response Characteristics

DeepSeek: Provides a detailed response with 46 sentences.

Gemini: Provides a direct response with 53 sentences.

Mistral: Provides a direct response with 52 sentences.

Key Takeaways

Each model brings unique strengths to this type of query
Response styles vary significantly between models
Consider your specific use case when choosing between these models

Try This Comparison Yourself

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This comparison was generated using the SNEOS AI Comparison ToolPublished: October 02, 2025 | Models: DeepSeek, Gemini, Mistral