CFPB submits final Section 1071 reconsideration rule to OMB for review

On April 16, the CFPB submitted a final rule titled “Small Business Lending Data Collection Under the Equal Credit Opportunity Act Reconsideration” (RIN 3170-AB40) to the OMB’s Office of Information and Regulatory Affairs (OIRA) for review under Executive Order 12866 (as amended). The submission follows the Bureau’s November 2025 proposed rule to revise certain provisions of its 2023 final rule implementing Section 1071 of the Dodd-Frank Act, which amends the ECOA to require financial... By: Orrick, Herrington & Sutcliffe LLP