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Discriminatory Lending Practices

Ballard Spahr LLP

CFPB’s Final Rule Recalibrates Fair Lending Enforcement: A Return to Clarity and Core Statutory Principles

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On April 22, 2026, the Consumer Financial Protection Bureau (CFPB), under Acting Director Russell Vought, issued a significant final rule reshaping the agency’s approach to fair lending enforcement under the Equal Credit...more

Orrick, Herrington & Sutcliffe LLP

NYDFS reiterates companies’ fair lending obligations under state banking laws

On April 22, NYDFS issued an industry letter to all entities regulated by the department under the New York Banking Law, outlining their obligations under New York’s fair lending law, N.Y. Executive Law § 296-a. The letter...more

Orrick, Herrington & Sutcliffe LLP

Court dismisses DOJ predatory lending and land sales case, finds settlement ‘bears little relationship’ to claims

On April 28, the U.S. District Court for the Southern District of Texas dismissed with prejudice a predatory lending and land sales case, while expressing serious concerns about the parties’ settlement agreement (covered by...more

Husch Blackwell LLP

CFPB Finalizes Major Regulation B Overhaul: Disparate Impact Out, Discouragement Narrowed, and SPCPs Restricted

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For the first time since its enactment and implementation nearly 50 years ago, the CFPB is taking the position that ECOA does not authorize disparate-impact liability. On April 22, 2026, the CFPB published its final rule...more

Troutman Pepper Locke

Point-of-Sale Finance Series: Fair Lending Risks at the Checkout Counter — Payments Pros – The Payments Law Podcast

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In this special joint episode of Payments Pros and The Consumer Finance Podcast, guest host Taylor Gess joins Chris Willis and Lori Sommerfield to unpack fair lending risks in point-of-sale finance. They explain how...more

Troutman Pepper Locke

Colony Ridge Settlement: DOJ Bypasses Court Oversight After Judge’s Objections

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As reported by Law360, the U.S. Department of Justice (DOJ) has decided to move forward with its $68 million settlement with Colony Ridge Development LLC without seeking court approval or ongoing judicial oversight. The...more

Orrick, Herrington & Sutcliffe LLP

Democratic senators urge agencies to reinstate disparate impact liability references

On February 25, a group of Democratic senators issued a letter urging the OCC, FDIC, and NCUA to reinstate references to disparate impact liability in their respective organizations’ supervisory guidance. The letter argued...more

Hudson Cook, LLP

Federal Agencies' Withdrawal of Joint Statement on Fair Lending Likely to Reduce Credit Opportunities for Non-Citizens

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On January 12, 2026, the Consumer Financial Protection Bureau and the Department of Justice withdrew their October 2023 joint statement regarding the implications of a creditor's consideration of an individual's immigration...more

Orrick, Herrington & Sutcliffe LLP

Washington, D.C., attorney general sues lender over alleged housing discrimination in rent-controlled units

On February 20, the Office of the Attorney General for the District of Columbia (OAG) announced that it has filed a complaint in the Superior Court of the District of Columbia alleging that a real estate lending firm engaged...more

Troutman Pepper Locke

Colony Ridge Settlement With Texas and US Department of Justice Reflects Shift in Enforcement Priorities

Troutman Pepper Locke on

On March 6, 2026, a U.S. district court will consider whether to approve a settlement agreement resolving parallel lawsuits by the Texas attorney general (AG) and the federal government against Houston-area developer Colony...more

Orrick, Herrington & Sutcliffe LLP

U.S. DOJ and Texas reach $68M settlement with developer in predatory lending and land sales case

On February 10, DOJ announced a settlement agreement, pending approval in the U.S. District Court for the Southern District of Texas, resolving claims brought by DOJ, the CFPB, and the state of Texas against a land developer...more

Troutman Pepper Locke

DOJ and Texas Reach No‑Penalty Settlement with Colony Ridge Over Alleged Predatory Mortgage Financing, Discriminatory Land Sales

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In December 2023, we blogged about lawsuits filed by the Consumer Financial Protection Bureau (CFPB or Bureau), the U.S. Department of Justice (DOJ), and later the State of Texas against Colony Ridge and related entities. The...more

Ballard Spahr LLP

Justice Department and State of Texas Settle Allegations Against Colony Ridge

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The Justice Department and State of Texas recently entered into a settlement agreement with Colony Ridge Development, LLC and related entities (Colony Ridge) to settle allegations that Colony Ridge violated certain federal...more

Hudson Cook, LLP

DOJ and State of Texas Announce Joint Settlement with a Private Land Developer for Allegedly Discriminating against Hispanic...

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DOJ and State of Texas announced a $68 million settlement of ECOA and FHA claims against a private land developer (the "Developer") concerning an alleged pattern or practice of discriminatory lending practices and high...more

Orrick, Herrington & Sutcliffe LLP

Senators pen letter urging CFPB to rescind its ECOA disparate impact rule

On February 3, several U.S. senators sent a letter to CFPB Acting Director Russell Vought urging the Bureau to rescind its proposed rule that would end the ECOA’s disparate impact test, which would prevent the CFPB from...more

Hudson Cook, LLP

CFS Bites of the Month - 2025 Annual Review - Nondiscrimination and Military Protection Law

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In this article, we share a timeline of monthly "bites" for the past year applicable to consumers protected by nondiscrimination and military protection laws....more

Hudson Cook, LLP

CFPB Proposes Changes to Regulation B

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On November 13, the Consumer Financial Protection Bureau published a Notice of Proposed Rulemaking proposing various revisions to Regulation B. ...more

Holland & Knight LLP

N.J. Attorney General Preserves Disparate Impact Theory of Lending Discrimination for Borrowers

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The Trump Administration issued an executive order in April 2025 directing federal agencies to no longer rely on the "disparate impact" theory of liability to find financial institutions and others guilty of discrimination...more

Hudson Cook, LLP

CFS Bites of the Month - 2025 Annual Review - Student Lending

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In this article, we share a timeline of monthly "bites" for the past year applicable to student lending....more

Orrick, Herrington & Sutcliffe LLP

HUD moves to eliminate disparate impact rules under Fair Housing Act

On January 14, HUD proposed a rule to rescind its regulations addressing disparate impact liability under the Fair Housing Act. The agency explained that questions about whether a housing practice has an unjustified...more

Orrick, Herrington & Sutcliffe LLP

U.S. Supreme Court denies certiorari in discrimination case

On January 12, the U.S. Supreme Court announced it had denied certiorari in a case challenging a 2nd U.S. Circuit Court of Appeals decision that addressed issues under the Fair Housing Act, including standards for equitable...more

Alston & Bird

Expansion of New York’s Community Reinvestment Act Via New Regulation

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Last week, the New York State Department of Financial Services (DFS) announced a new regulation designed to ensure that licensed nonbank mortgage bankers in New York (“mortgage lenders”) meet the needs of the communities they...more

Sheppard

CFPB and DOJ Withdraw Joint Statement Addressing ECOA and Noncitizen Borrowers

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On January 12, the CFPB and DOJ withdrew their October 2023 joint statement addressing how creditors’ consideration of immigration or citizenship status may intersect with the ECOA. The joint statement, published in the...more

Troutman Pepper Locke

New York Extends CRA Obligations to Nonbank Mortgage Lenders

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New York has adopted new regulations, 3 NYCRR Part 120, that will extend New York’s Community Reinvestment Act (CRA) obligations to certain nonbank mortgage lenders operating in the state. Effective July 7, 2026, the rule...more

Cooley LLP

CFPB and DOJ Withdraw 2023 Statement on ECOA and Noncitizen Borrowers

Cooley LLP on

On January 12, 2026, the Consumer Financial Protection Bureau (CFPB) and the Department of Justice (DOJ) formally withdrew their October 2023 joint statement addressing creditors’ consideration of immigration status under the...more

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