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Creditors Equal Credit Opportunity Act Adverse Action

Ballard Spahr LLP

Regulatory Requirements Related to Adverse Action Notifications

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As part of the Federal Reserve Board’s Outlook Live Webinar series, on July 17, 2025, examiners from the Minneapolis and Chicago Federal Reserve Banks hosted a webinar to discuss the regulatory requirements related to adverse...more

Ballard Spahr LLP

CFPB Revisits Adverse Action Notice Requirements When Using Artificial Intelligence or Complex Credit Models

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In May 2022, the CFPB issued Circular 2022-3 addressing Equal Credit Opportunity Act (ECOA) adverse action notice requirements in connection with credit decisions based on algorithms. The CFPB is now revisiting the issue in...more

Goodwin

CFPB Says Creditors Must Provide Reasons For Taking Adverse Action, Even When Relying On AI

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On May 26th, 2022, the Consumer Financial Protection Bureau (“CFPB”) published a Consumer Financial Protection Circular (the “Circular”), confirming that creditors must provide specific reasons for taking adverse action...more

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