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Fair Lending Disparate Impact

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

Troutman Pepper Locke

New Jersey's Big Bet on Disparate Impact: What the AG's New Rules Mean for Lenders and AI — Regulatory Oversight Podcast

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In this special crossover episode of Regulatory Oversight and The Consumer Finance Podcast, Chris Willis is joined by colleagues Lori Sommerfield and Matthew Berns to discuss New Jersey's sweeping new disparate impact...more

Troutman Pepper Locke

New Jersey's Big Bet on Disparate Impact: What the AG's New Rules Mean for Lenders and AI — The Consumer Finance Podcast

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In this special crossover episode of The Consumer Finance Podcast and Regulatory Oversight, Chris Willis is joined by colleagues Lori Sommerfield and Matthew Berns to discuss New Jersey's sweeping new disparate impact...more

MoFo Tech

AI Trends For 2026 - AI and Algorithmic Bias in Financial Services

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With the exponential growth of AI technologies, financial institutions must address algorithmic bias head on, as it is one of the most significant emerging issues in certain core activities, including credit underwriting,...more

Dorsey & Whitney LLP

Responding to the CFPB’s Proposal to Eliminate Disparate Impact and Related Fair Lending Protections of Regulation B

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On November 13, 2025, the CFPB published in the Federal Register a significant proposed rule (the “Proposal”) that would radically diminish the protections against discriminatory lending practices afforded to protected...more

Baker Donelson

Disparate Impact Liability Is Top of Mind – Is Your Financial Institution Ready?

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As 2026 kicks into high gear, all signs point to another year of jaw-dropping headlines as federal financial regulators move swiftly to implement many of the policy changes found in executive orders and other directives...more

Hinshaw & Culbertson - Consumer Crossroads

The CFPB’s Proposed Disparate Impact Amendments to Regulation B

Earlier this year, President Trump issued Executive Order 14281 (the “Executive Order”) directing a review of existing federal regulations and guidance documents that impose disparate impact liability (sometimes referred to...more

Orrick, Herrington & Sutcliffe LLP

CFPB’s 2024 fair lending report outlines new focus in fair lending oversight

On December 23, the CFPB released its annual fair lending report, which reviews the agency’s enforcement and supervision activities for 2024 and described a significant policy shift in fair lending oversight since the close...more

Ballard Spahr LLP

CFPB and DOJ Withdraw Joint Statement On Consideration Of Immigration Status Under ECOA

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As previously reported, in October 2023 the CFPB and DOJ issued a joint statement regarding “the potential civil rights implications of a creditor’s consideration of an individual’s immigration status under the Equal Credit...more

Mayer Brown

Attention Lenders: New Jersey Issues Disparate Impact Regulations

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The New Jersey Division on Civil Rights (the “Division”) recently finalized revisions to the state’s disparate impact regulations. The regulations implement New Jersey’s Law Against Discrimination (“LAD”), which state...more

Troutman Pepper Locke

New Jersey Adopts Disparate Impact Rules Under LAD, With Broad Reach Across Housing, Lending, Employment, And Other Fields, With...

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On December 17, New Jersey announced its adoption of what its Attorney General is calling the “most comprehensive state-level disparate impact regulations in the country.” Effective December 15, 2025, the Division on Civil...more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposed Rule Dramatically Revises ECOA

On November 13, the CFPB issued a sweeping proposed rule to overhaul Regulation B, arguably the most far-reaching ECOA rewrite in the agency’s history. The proposal would eliminate disparate-impact liability under ECOA,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways From Fair Lending 2025: Navigating Turbulent Waters

On November 3, 2025, Skadden and Troutman co-hosted a conference in Washington, D.C. titled “Fair Lending 2025: Navigating Turbulent Waters.” Leading the conference were Anand Raman, head of Skadden’s Consumer Financial...more

Ballard Spahr LLP

CFPB wants to eliminate disparate-impact claims under ECOA

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The CFPB has issued a proposed rule that would make substantial changes to Regulation B under the Equal Credit Opportunity Act (ECOA). In one of the most significant changes, the bureau has preliminary determined that...more

Mayer Brown

CFPB Proposes Narrowing ECOA Regulations

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The Consumer Financial Protection Bureau (“CFPB”) has issued its proposed rule scaling back the interpretation of and regulations under the Equal Credit Opportunity Act (“ECOA”). While the agency placed the proposal on its...more

Bradley Arant Boult Cummings LLP

Regulation B Revisited: CFPB Proposes Amendments Addressing Disparate Impact, Discouragement, and Special Purpose Credit Programs

On November 13, 2025, the Consumer Financial Protection Bureau (CFPB) released a Notice of Proposed Rulemaking (NPRM) amending Regulation B – the regulation implementing the Equal Credit Opportunity Act (ECOA)....more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes changes to Regulation B on disparate impact and other provisions

On November 13, the CFPB published a proposed rule in the Federal Register to amend Regulation B, which implements the ECOA. ...more

GeoDataVision

Statistical Significance

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Statistical significance, using a 5% probability threshold, is a key tool in redlining allegations under the disparate impact theory, measuring the likelihood that a bank's low performance in minority areas occurred by...more

Troutman Pepper Locke

CFPB’s Proposed Reg B Overhaul: Ending ECOA Disparate Impact, Narrowing Discouragement, and Reshaping SPCPs

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The Consumer Financial Protection Bureau (CFPB or Bureau) has proposed an unprecedented, far‑reaching rewrite of Regulation B (Reg B) under the Equal Credit Opportunity Act (ECOA). If finalized, the proposed rule would...more

GeoDataVision

Regulatory Compliance: When Statistical Significance Fails

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In October 2021, the then Attorney General, Merrick Garland, announced the Combating Redlining Initiative (“CRI”) Shortly thereafter, federal banking regulators began a record-breaking number of referrals to the Department of...more

GeoDataVision

Executive Order 14281: The End of Fair Lending Law Enforcement Through Use of the Disparate Impact Legal Theory?

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Dean Stockford and Len Suzio welcome Lori Sommerfield of Troutman Pepper Locke LLP to discuss President Trump’s Executive Order 14281, which limits federal use of the disparate impact theory in fair lending enforcement,...more

Orrick, Herrington & Sutcliffe LLP

Mortgage lender files writ of cert. with SCOTUS

On August 25, the U.S. Supreme Court received a writ of certiorari from a mortgage lender (the petitioner) challenging a decision by the U.S. Court of Appeals for the 2nd Circuit upholding a jury verdict finding the...more

Troutman Pepper Locke

FDIC Updates Consumer Compliance Examination Manual to Eliminate Disparate Impact Analysis in Response to President Trump’s...

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On August 29, the Federal Deposit Insurance Corporation (FDIC) announced updates to its Consumer Compliance Examination Manual, marking a pivotal shift in how potential discrimination under the Equal Credit Opportunity Act...more

Husch Blackwell LLP

FDIC Removes Disparate Impact Theory from Compliance Exam Manual

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Before the Labor Day holiday weekend, the Federal Deposit Insurance Corporation (FDIC) updated the fair lending and unfair, deceptive act or practices (UDAP) chapters of its Consumer Compliance Examination Manual to remove...more

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