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CFPB Extending Small Business Data Collection Compliance Deadline
The Consumer Financial Protection Bureau (CFPB) recently announced it is extending the compliance deadline for the small business data collection final rule. A federal district court in Texas stayed the rule for certain lenders on July 31, 2023, pending the outcome of the Supreme Court’s decision in CFPB v. CFSA. On Oct. 26, 2023, the stay was extended to all lenders.
The CFPB announced it will issue an interim rule extending the compliance deadlines. The extended compliance dates are as follows:
| Compliance tier | Original compliance date | New compliance date | First filing deadline |
|---|---|---|---|
| Tier 1 institutions (highest volume lenders) | Oct. 1, 2024 | July 18, 2025 | June 1, 2026 |
| Tier 2 institutions (moderate volume lenders) | April 1, 2025 | Jan. 16, 2026 | June 1, 2027 |
| Tier 3 institutions (smallest volume lenders) | Jan. 1, 2026 | Oct. 18, 2026 | June 1, 2027 |
Should you have any questions regarding small business data collection compliance, Doeren Mayhew’s regulatory compliance pros stand ready to assist.
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John Zasada is a Principal in Doeren Mayhew's Financial Institutions Group, where he assists financial institutions in navigating regulatory compliance.
