News & Analysis as of

Discriminatory Lending Practices Disparate Impact Consumer Financial Products

Troutman Pepper Locke

In Response to President Trump’s Executive Order, the OCC Removes Disparate Impact References from Fair Lending Examination Manual

Troutman Pepper Locke on

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

Orrick, Herrington & Sutcliffe LLP

HUD restores 2013 discriminatory effects rule

On March 17, HUD announced the submission of a final rule—Reinstatement of HUD’s Discriminatory Effects Standard—which would rescind the agency’s 2020 regulation governing Fair Housing Act (FHA or the Act) disparate impact...more

King & Spalding

The Implications of a Revived Disparate Impact Doctrine Under a Biden CFPB

King & Spalding on

Every change in presidential administration results in shifts to agencies’ policy priorities and enforcement efforts. In a Biden Administration, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”), in particular,...more

Ballard Spahr LLP

FTC settles lawsuit against car dealer alleging discriminatory pricing practices

Ballard Spahr LLP on

The FTC recently announced a settlement of its lawsuit filed in a New York federal district court against a New York City car dealership and its individual general manager in which the FTC alleged that the defendants...more

Ballard Spahr LLP

Senate Dems Target For-Profit Colleges and Federal Student Loan Servicers and Collectors in Letter to Dept. of Education

Ballard Spahr LLP on

Last week, Senators Elizabeth Warren, Kamala Harris and Cory Booker sent a letter to the U.S. Department of Education’s Office of Civil Rights (OCR) requesting information about how OCR “plans to address alarming racial...more

Ballard Spahr LLP

Will the NYDFS pick up the baton on disparate impact auto dealer pricing?

Ballard Spahr LLP on

If you’ve followed the status of the CFPB’s enforcement actions under the Equal Credit Opportunity Act related to auto dealer finance charge participation, you probably would have concluded that those cases are unlikely to...more

Ballard Spahr LLP

Industry trade groups urge HUD to make significant changes to its disparate impact rule; state attorneys general oppose changes

Ballard Spahr LLP on

The American Bankers Association jointly with state bankers associations, the American Financial Services Association, and the Mortgage Bankers Association are urging the U.S. Department of Housing and Urban Development (HUD)...more

Ballard Spahr LLP

Republican members of House Financial Services Committee release new report on CFPB’s auto finance actions

Ballard Spahr LLP on

Republican members of the House Financial Services Committee recently released a report, prepared by the Republican Staff of the Committee, titled “Unsafe at Any Bureaucracy, Part III: The CFPB’s Vitiated Legal Case Against...more

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