On June 25, 2024, the CFPB issued an interim final rule to extend compliance deadlines for the small business lending rule. This is after a federal court in Texas required the CFPB to extend the rule’s compliance deadlines to compensate for the period stayed pending the Supreme Court’s decision in CFPB v. CFSA.
Following the recent Supreme Court decision in CFPB v. CFSA, the CFPB extended compliance dates by 290 days, which is the time that has elapsed between the Texas court’s first issuance of a stay and the Supreme Court’s decision in CFPB v. CFSA. The new deadlines will be as follows:
Start of collection of data:
July 18, 2025: Lenders with the highest volume of small business loans
January 16, 2026: Lenders with the moderate volume of small business loans
October 18, 2026: Lenders with the smallest volume of small business loans
Submission of data:
June 1, 2026: Lenders with the highest volume of small business loans
June 1, 2027: Lenders with the moderate volume of small business loans
June 1, 2027: Lenders with the smallest volume of small business loans
Lenders may continue using their small business originations from 2022 and 2023 to determine their initial compliance date, or instead use their originations from 2023 and 2024. The CFPB also said that it does not intend to assess penalties for reporting errors for the first 12 months of collection, and it intends to conduct examinations only to assist lenders in diagnosing compliance weaknesses, so long as lenders engage in good faith compliance efforts.
Read the CFPB’s announcement here.
The interim final rule can be found here.