News & Analysis as of

Underwriting Disparate Impact

Mayer Brown

New York State Department of Financial Services Issues Proposed Artificial Intelligence Circular Letter

Mayer Brown on

On January 17, 2024, the New York State Department of Financial Services (“NYSDFS”) released a proposed circular letter addressing the use of external consumer data and information sources (“ECDIS”) and artificial...more

Akin Gump Strauss Hauer & Feld LLP

DFS Issues Guidance to Life Insurers on Use of “External Data” in Underwriting Decisions

On January 18, 2019, New York’s Department of Financial Services (DFS) issued Circular Letter No. 1 (2019) to advise life insurers regarding the type of data that they may use when underwriting policies. The guidance was...more

MoFo Reenforcement

CFPB Refers Another Auto Finance Company to DOJ on Disparate Impact Allegations

MoFo Reenforcement on

Not long after taking action against American Honda Finance Corporation under the disparate impact doctrine for allegedly discriminatory auto loan pricing, the CFPB has struck again—this time reportedly referring Santander...more

Pullman & Comley, LLC

Not-So-Sudden Impact: Insurers Face A New Breed Of Claim Under the Fair Housing Act (Part 3 of 3)

Pullman & Comley, LLC on

This is the final article of a three-part series about two recent decisions by federal courts in Connecticut and California: Viens v. America Empire Surplus Lines Ins. Co., No. 3:14cv952 (D. Conn. June 23, 2015), and Jones v....more

Pullman & Comley, LLC

Not-So-Sudden Impact: Insurers Face A New Breed Of Claim Under the Fair Housing Act (Part 1 of 3)

Pullman & Comley, LLC on

Late in June, in Texas Dept. of Housing v. Inclusive Communities, No. 13–1371 (U.S. June 25, 2015), the U.S. Supreme Court ended years of debate by embracing a “disparate impact” claim against a housing authority under the...more

Dechert LLP

American Bankers Association Real Estate Lending Conference - Qualified Mortgages: A Sea Change For Mortgage Lenders

Dechert LLP on

In This Presentation: - The Qualified Mortgage (QM) Rule - Small Creditor QM Proposal - The Ability-to-Repay (ATR) Rule: What It Says and What It Means - Liability for Failure to Comply with the ATR and QM...more

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