Clean Data First: Section 1071 Webinar

Compliance in Practice

Readiness Beyond the Rule

The revised Section 1071 final rule took effect June 30, 2026. It raised the coverage threshold from 100 to 1,000 covered originations in each of the two preceding calendar years and set a single compliance date. What it did not settle is what a future Consumer Financial Protection Bureau (CFPB) does with the data once institutions start filing it.

This session takes the forward-looking view rather than repeating the requirements. It picks up where our June 10 session left off, when the case was that 2027 is the real deadline, and asks the next question: if 2027 is the build year, what should institutions be building toward?

Dates set by the revised rule

Rule effectiveJune 30, 2026
Data collection beginsJanuary 1, 2028
First submission dueJune 1, 2029

Agenda

What We Will Cover

A discussion, not a requirements walkthrough. If you attended in June, we will say plainly what has changed since.

What the Revised Rule Settled

A fast orientation on the threshold, the single compliance date, and the 12-month grace period for 2028 data. Plus the point that matters most for institutions now out of scope: the carve-out removed a reporting obligation, not fair lending exposure under the Equal Credit Opportunity Act (ECOA) or the Community Reinvestment Act (CRA).

The Data Question: Collected, Not Reported

Institutions will capture far more about small business credit decisions than the rule requires them to report. Elena and Anurag discuss why that gap matters, and what institutions can control now: what they capture, how consistently, and how they document the reasons behind decisions.

Readiness Decisions Worth Making in 2027

Data hygiene as a forward hedge, running fair lending and redlining analysis on small business credit before it is required, what to keep doing if you are below the threshold, and where SBL/1071 supports collection, validation, and analysis.

Q&A and Next Steps

Open questions from attendees, with a pointer to the January 1, 2028 collection start and the June 1, 2029 first submission.

Audience

Who Should Attend

Built for the teams that will own small business lending data, whether or not their institution reports under the revised rule.

Compliance Officers

Fair Lending Officers

Small Business Lending Leaders

CRA Program Leads

Risk Managers

Institutions Near the 1,000 Threshold

Featured Presenters

Who Is Leading the Discussion

An internal voice for continuity with June, and an outside practitioner's read on what comes next.

Dr. Anurag Agarwal

Founder and President, RiskExec

Anurag founded RiskExec and built the original platform. He has spent more than 30 years in fair lending technology, starting while he earned his PhD in Operations Research, Statistics, and Management Science at the University of Tennessee, Knoxville. He co-founded Compliance Solutions in 2001 and founded Risk Management Solutions Inc. (RMS) in 2006, which Asurity Technologies acquired in 2015. RiskExec became a standalone company in January 2025. He speaks often at American Bankers Association (ABA) and Mortgage Bankers Association (MBA) conferences, and in 2026 received the Stevie® Awards for Technology Excellence Lifetime Achievement Award in Financial Technology.

Elena Babinecz

Shareholder, Baker Donelson

Elena spent more than 12 years at the Consumer Financial Protection Bureau (CFPB) before joining Baker Donelson. As Deputy Assistant Director in the Office of Regulations, she led the agency's interpretation of the Equal Credit Opportunity Act (ECOA) and Regulation B. She managed the rulemaking team behind the small business lending data collection rule implementing Section 1071 of the Dodd-Frank Act, and served as the agency's Implementation Team Lead for the 2015 Home Mortgage Disclosure Act (HMDA) rule. Before the CFPB, she spent more than a decade in private practice advising financial services clients through fair lending examinations and investigations.

Clean Data First: Preparing for Section 1071 Collection and Analysis