The 2027 risk and compliance priorities for US banks and credit unions rest on three fixed dates and two open questions:
- The GENIUS Act and the OCC’s stablecoin rule take effect on 18 January 2027
- FDIC signage compliance falls on 1 April 2027
- Section 1071 data collection starts on 1 January 2028
- FinCEN’s AML/CFT program rule (no date as of publishing)
- The CFPB’s Section 1033 rewrite (no date as of publishing)
What follows sets the calendar’s scope, turns it into a plan, gives the timeline, reviews and what is unknown as of publishing this article.
What the 2027 Compliance Calendar Covers
The calendar lists federal rules with a fixed effective or compliance date between November 2026 and January 2028, plus federal rules that are proposed but not final.
The FDIC signage rule covers FDIC-insured institutions, so credit unions follow NCUA requirements instead. The OCC’s GENIUS Act rule covers national banks, federal savings associations and other OCC-supervised entities that issue payment stablecoins. Section 1071 applies only to lenders above its origination threshold.
Examiner evidence, AI governance and operational resilience are covered in a separate review of 2027 banking trends.
Turning the Calendar Into a Compliance Plan
A date on a calendar becomes a plan through five steps:
1. Record applicability
For each rule, document whether it applies, which business lines it touches and who made the decision.
2. Assign an owner and a milestone
Name one accountable owner and set a readiness milestone ahead of the date, with the lead time set in the institution’s own policy.
3. Map the changes
Link each rule to the policies, procedures, controls, disclosures and systems it changes, so testing can confirm each change before the date.
4. Watch pending rules
Keep each proposal on a watch list with the event that starts work, usually publication of a final rule and its compliance period.
5. Report status
Show progress against each milestone in the board or committee reporting the institution already produces.
These steps are the core of regulatory change management but the calendar supplies the dates for each.
2027 Regulatory Timeline for Banks and Credit Unions
The table lists each fixed date on the 2027 regulatory compliance calendar, what the rule requires and whom it covers.
| Date | Rule | What it requires | Who it applies to |
|---|---|---|---|
| 2 Nov 2026 | OCC and FDIC rule on unsafe or unsound practices and MRAs takes effect | Defines unsafe or unsound practice; focuses matters requiring attention on material financial risk | OCC- and FDIC-supervised institutions |
| 16 Nov 2026 | Comments close on the interagency third-party risk management proposal | Proposed guidance that would replace the 2023 guidance | Banks and credit unions |
| 18 Jan 2027 | GENIUS Act and the OCC’s final rule take effect | Reserve assets, redemption, risk management and custody standards for payment stablecoin issuers | OCC-supervised issuers and their subsidiaries |
| 1 Apr 2027 | FDIC signage compliance date | Revised FDIC official sign and disclosure rules for digital deposit channels and ATMs | FDIC-insured institutions |
| Calendar year 2027 | Second Section 1071 look-back year | Coverage depends on 1,000 or more covered originations in each of 2026 and 2027, or optionally 2025 and 2026 | Lenders to small businesses |
| 1 Jan 2028 | Section 1071 compliance date | Collect small business lending data from this date; grace period for good-faith errors through 31 Dec 2028 | Covered lenders |
Rules Whose 2027 Dates Are Not Yet Known
FinCEN AML rule
FinCEN proposed revised AML/CFT program requirements on 7 April 2026, and comments closed on 9 June 2026. The new requirements would take effect 12 months after a final rule, and FinCEN has not announced when one will be issued. The OCC, FDIC and NCUA proposed matching changes, and the Federal Reserve followed on 7 July 2026.
Section 1033
A federal court in the Eastern District of Kentucky has enjoined the CFPB’s 2024 personal financial data rights rule while the Bureau reconsiders it. The CFPB sent a revised proposal for White House review in August 2026.
Basel III endgame
The Federal Reserve, FDIC and OCC re-proposed the capital rules on 19 March 2026, with comments due 18 June 2026, and did not propose an effective date.
Third-party guidance
Whether the September 2026 proposal is finalized, and when, depends on the agencies’ review after comments close.
Frequently Asked Questions
When Does the GENIUS Act Take Effect?
The GENIUS Act takes effect on 18 January 2027, 18 months after it was signed on 18 July 2025, because that date comes before the alternative of 120 days after final regulations. The OCC’s final rule, issued on 21 October 2026, takes effect on the same date; the OCC is handling BSA, AML and sanctions requirements in a separate rulemaking with Treasury.
Is the Section 1033 Open Banking Rule in Effect?
No. The CFPB finalized the rule in October 2024, but a federal court has enjoined enforcement while the Bureau reconsiders it, so the original compliance dates do not apply until a revised rule sets new ones.
When Must Lenders Comply with Section 1071?
Covered lenders begin collecting small business lending data on 1 January 2028 under the CFPB’s revised rule issued on 1 May 2026. A lender is covered if it originated 1,000 or more covered credit transactions in each of the two preceding calendar years, and small businesses are those with gross annual revenue of $1 million or less.
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