§ 1071 · Coverage threshold
Am I covered under Section 1071?
Coverage is based on transaction volume, not institution type. Enter your origination counts to see where you likely stand.
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How the threshold actually works
Under the May 2026 revised rule, an institution is in the initial covered group if it originated 1,000 or more covered small business credit transactions in each of the two preceding calendar years — 2026 and 2027, for institutions determining their status ahead of the January 1, 2028 compliance date. That's a significant increase from the original 2023 rule's 100-transaction threshold.
"Covered small business credit transaction" is a defined term with its own exclusions — this tool doesn't attempt to sort those out for you. It's a quick read on the headline threshold, not a substitute for a documented coverage analysis.
Why this comes up so often in equipment finance
Equipment finance lenders and brokers hit this threshold more often than their asset size might suggest. A mid-market equipment lender running a high volume of small-ticket loans and finance leases can clear 1,000 transactions a year well before a bank of similar size would, simply because the deal structure is high-frequency and lower-dollar. If that describes your book of business, it's worth running the numbers above now rather than waiting until 2027.
One nuance worth flagging: Section 1071 covers credit transactions. Loans and finance leases (structured as credit) generally count; true operating leases may not, depending on how a given transaction is structured. Confirm the treatment of your specific lease and loan products with counsel rather than assuming either way.
This is general information, not legal or compliance advice. Consult qualified counsel or a compliance professional for guidance specific to your institution.