In a new message to community bankers, ICBA President and CEO Rebeca Romero Rainey outlines the current state of the Consumer Financial Protection Bureau’s problematic 1071 rule, including ICBA’s efforts to continue its fight to protect community banks and small businesses from this harmful and burdensome regulation.
Key Dates: The final rule compliance implementation dates apply as follows:
Covered financial institutions originating at least 2,500 covered credit transactions for small businesses in each of calendar years 2022 and 2023 shall comply beginning Oct. 1, 2024.
Covered financial institutions originating less than 2,500 but at least 500 covered credit transactions for small businesses in each of calendar years 2022 and 2023 shall comply beginning April 1, 2025.
Covered financial institutions originating less than 500 but at least 100 covered credit transactions for small businesses in each of calendar years 2022 and 2023 shall comply beginning Jan. 1, 2026.
State of Court Filings: As part of ICBA’s efforts to ensure a recent district court decision granting temporary injunctive relief from the rule applies broadly to community banks, ICBA, the Independent Bankers Association of Texas and Texas First Bank moved to intervene in the TBA v. CFPB case pending in the U.S. District Court for the Southern District of Texas. The court granted this request, and ICBA, IBAT and Texas First Bank are now asking the district court to enter a preliminary injunction prohibiting the CFPB from enforcing the 1071 rule nationwide or, alternatively, for all ICBA and IBAT members.
Grassroots Resources: Given the unsettled state of 1071, ICBA continues calling on community bankers to keep up the pressure with policymakers. Community bankers can use ICBA’s Be Heard grassroots action center to urge their lawmakers to support a resolution to block the 1071 rule as well as ICBA’s customizable resources to educate and engage their customers on the issue.
“While there is much information—and more than a little misinformation—circulating on the state of the 1071 rule and ongoing legal challenges, community bankers can rest assured that ICBA’s multipronged efforts continue to advance on several fronts,” Romero Rainey wrote.
