On July 14, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2025-16, announcing the removal of references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and...more
7/16/2025
/ Anti-Discrimination Policies ,
Banks ,
Borrowers ,
Consumer Financial Products ,
Deregulation ,
Discriminatory Lending Practices ,
Disparate Impact ,
Equal Access to Credit ,
Executive Orders ,
Fair Lending ,
Financial Regulatory Reform ,
Financial Services Industry ,
Handbooks ,
Lenders ,
OCC ,
Regulatory Authority ,
Regulatory Requirements ,
Trump Administration
In this episode of The Consumer Finance Podcast, Chris Willis and Lori Sommerfield discuss the Consumer Financial Protection Bureau's (CFPB) recent withdrawal of more than 60 pieces of informal guidance, focusing on those...more
In this episode of The Consumer Finance Podcast, Chris Willis is joined by Troutman Pepper Locke colleagues Lori Sommerfield and Lane Page to dissect two unexpected fair lending developments under the new Trump...more
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) released a memo to staff outlining its new supervision and enforcement priorities for 2025....more
4/18/2025
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDCPA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgages ,
Regulatory Reform ,
Regulatory Requirements ,
Supervisory Guidance ,
Trump Administration
In this episode of the Consumer Finance Podcast, Chris Willis, co-leader of Troutman Pepper Locke's Consumer Financial Services Regulatory practice, delves into the current state of machine learning and artificial...more
In this third episode of the Year in Review series of The Consumer Finance Podcast, host Chris Willis is joined by Lori Sommerfield, a partner in Troutman Pepper Locke’s Consumer Financial Services Practice Group, to discuss...more
2/6/2025
/ Artificial Intelligence ,
Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Enforcement Actions ,
Fair Lending ,
Financial Regulatory Reform ,
Redlining ,
Section 1071 ,
Trump Administration ,
UDAAP
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) released its latest Supervisory Highlights report, focusing on the use of advanced technologies in credit scoring models. ...more
1/22/2025
/ Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Scores ,
Data Privacy ,
Data Protection ,
Discriminatory Lending Practices ,
ECOA ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Machine Learning ,
Regulatory Requirements ,
Risk Management
Join host Chris Willis and guests Lori Sommerfield and Joseph Reilly in this episode of The Consumer Finance Podcast as they delve into the CFPB's recent study on differential treatment in small business lending. Discover the...more
In a significant development, the Consumer Financial Protection Bureau (CFPB or Bureau) has finally reached a settlement with Townstone Financial, Inc. (Townstone) in the first redlining case brought against a nonbank...more
11/6/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Loan Applications ,
Mortgage Lenders ,
Race Discrimination ,
Redlining ,
Settlement
On October 29, New Jersey Attorney General Matthew Platkin and the state’s Division on Civil Rights (DCR) released a report detailing the findings of a multi-year investigation into Republic First Bank (Republic) and its...more
11/1/2024
/ Banks ,
Consumer Financial Products ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgages ,
Race Discrimination ,
Real Estate Transactions ,
Redlining
On October 15, the Consumer Financial Protection Bureau (CFPB or Bureau) and the Department of Justice (DOJ) announced that they reached a settlement with Fairway Independent Mortgage Corporation (Fairway). This settlement...more
10/18/2024
/ Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Loan Applications ,
Mortgage Lenders ,
Race Discrimination ,
Redlining ,
Settlement
On October 10, the U.S. Department of Justice (DOJ) announced a landmark redlining settlement with Citadel Federal Credit Union (Citadel), marking the first such agreement with a credit union in the DOJ’s history. This...more
10/14/2024
/ Consumer Financial Products ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
ECOA ,
Enforcement Actions ,
Equal Access to Credit ,
Fair Housing Act (FHA) ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Loans ,
Mortgages ,
Race Discrimination ,
Redlining ,
Statutory Violations
As discussed, in a recent letter, the Chairman of the National Credit Union Administration (NCUA) outlined the agency’s supervisory priorities for 2024. In this post, we delve deeper into the area of consumer protection...more
2/7/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Unions ,
ECOA ,
Fair Lending ,
Financial Services Industry ,
Loans ,
NCUA ,
Popular ,
Regulation Z ,
Supervisory Guidance ,
Truth in Lending Act (TILA)
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/1/2024
/ Automotive Loans ,
Banks ,
Class Action ,
Consumer Bankruptcy ,
Consumer Financial Products ,
Debt Collection ,
Digital Assets ,
Fair Lending ,
Financial Services Industry ,
FinTech ,
Mortgages ,
Student Loans ,
Tribal Loans ,
Uniform Commercial Code (UCC)
On December 19th, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a report highlighting consumers’ experiences with overdraft and nonsufficient funds (NSF) fees. The report found that roughly a quarter of...more
12/21/2023
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Dodd-Frank ,
Fair Lending ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Insufficient Funds ,
Overdraft Fees ,
Regulation Z ,
Rulemaking Process ,
Truth in Lending Act (TILA) ,
UDAAP
Last week, the annual Community Reinvestment Act & Fair Lending Colloquium took place in Austin, Texas. Two officials from the U.S. Department of Justice (DOJ) discussed in detail the “Combatting Redlining Initiative” led by...more
11/21/2023
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Mortgage Lenders ,
Race Discrimination ,
Redlining
In the last three weeks, the U.S. Department of Justice (DOJ) reached two more settlements with lenders under its Combatting Redlining Initiative, which began in October 2021. On September 27, the DOJ announced that...more
10/23/2023
/ Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Loan Applications ,
Mortgage Lenders ,
Race Discrimination ,
Redlining ,
Settlement
On July 26, the Consumer Financial Protection Bureau (CFPB or Bureau) released the summer edition of its Supervisory Highlights report, providing a high-level overview of alleged unfair, deceptive, or abusive acts or...more
7/28/2023
/ Automated Clearing House (ACH) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Debt Collectors ,
Fair Lending ,
Financial Services Industry ,
Military Lending Act ,
Mortgages ,
Payday Lending Rule ,
Supervisory Highlights ,
UDAAP
The American Association of Bank Directors (AABD) recently published the second edition of its Practical Handbook on Fair Lending for Bank Directors and Executive Officers (the Handbook), updating the first edition of the...more
As shown by a new report, the Consumer Financial Protection Bureau (CFPB or Bureau) is focusing its fair lending work on mortgage origination and pricing, small business lending, redlining, and the use of artificial...more
7/10/2023
/ Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
ECOA ,
Fair Lending ,
Financial Services Industry ,
HMDA ,
Mortgage Lenders ,
Mortgage Loan Originators ,
Mortgages ,
NCUA ,
Redlining
On April 5, the Federal Deposit Insurance Corporation (FDIC) released its Consumer Compliance Supervisory Highlights report, providing a high-level overview of consumer compliance issues identified by the agency during 2022...more
On February 9, the Federal Trade Commission (FTC) submitted its annual letter to the Consumer Financial Protection Bureau (CFPB) summarizing its activities enforcing the Equal Credit Opportunity Act (ECOA) and its...more
In the largest redlining settlement in the department’s history, the U.S. Department of Justice (DOJ) announced that an agreement has been reached to resolve redlining allegations against a Los Angeles-based bank. Under the...more
On December 23, New York Governor Hochul signed into law Assembly Bill A6328A amending New York Executive Law § 292, known as the New York State Human Rights Law, to add citizenship and immigration status to the list of...more
On December 6, during the 2022 Interagency Fair Lending Webinar, David Evans, a senior fair lending specialist with the Federal Deposit Insurance Corporation (FDIC), discussed some of the specific discrimination issues...more