The CFPB issued a guidance bulletin on compliance with the fair lending requirements of the Equal Credit Opportunity Act and its implementing regulation, Regulation B. The CFPB stated that it will continue to use the doctrine of disparate impact in its supervisory and enforcement activities, and concurred with the Interagency Task Force on Fair Lending’s 1994 Policy Statement on Discrimination in Lending, which provided three methods for establishing lending discrimination under ECOA: (1) overt evidence of discrimination; (2) evidence of disparate treatment; and (3) evidence of disparate impact.
Consumer Financial Services
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