UDAAP and Fair Lending Developments: 2024 Year-in-Review and 2025 Predictions — The Consumer Finance Podcast
Putting AI to Work in Compliance
On May 28, the U.S. Department of Justice filed a motion to terminate its redlining consent order against a New Jersey-based bank. The five-year order, entered in September 2022, resolved allegations that the banks violated...more
President Trump signed Executive Order 14281, “Restoring Equality of Opportunity and Meritocracy on April 23, 2025”. The EO proclaims a policy goal of eliminating “the use of disparate-impact liability in all contexts to the...more
On March 26, the CFPB, in its first press release in over 50 days, announced its intention to seek to vacate a redlining settlement previously imposed on a nonbank retail-mortgage creditor and broker based in Chicago. As...more
With the change in administration, enforcement actions at the federal level are expected to decrease, reflecting President Trump’s focus on deregulation. Indeed, during President Trump’s first term, the number of enforcement...more
Following lengthy litigation, the CFPB is attempting to close the books on its case against Townstone Financial alleging discriminatory lending practices and redlining African American neighborhoods in Chicago....more
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
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
The Justice Department announced that Citadel Federal Credit Union has agreed to pay more than $6.5 million to resolve allegations that it engaged in a pattern or practice of redlining majority-Black and Hispanic...more
Previously, I have written about regulatory enforcement of anti-redlining regulations. I pointed out the problems and potentially misleading statistical conclusions caused by the application of what is called a “REMA” or...more
In this month's article, we share some of our top "bites" for the prior and current month covered during the July 2024 webinar....more
As any bank professional regulatory compliance professional knows redlining is the hottest issue today and has been since Attorney General Merrick Garland announced the “Combatting Redlining Initiative” in October 2021. Since...more
In a recent article in National Mortgage Professional entitled "Manufacturing Fair Lending”, former chief of the Housing and Civil Enforcement Section at the Department of Justice under Attorney General William Barr, Paul...more
In emails in recent months we've warned bankers about the extremely aggressive enforcement of anti-redlining policies. This is becoming more and more obvious every day as more banks get threatened with referral to the DOJ....more
Since October 2021, the prudential bank regulators in concert with the Department of Justice have been pursuing the “Anti-Redlining Initiative” announced by Attorney General Merrick Garland on October 21, 2021. During that...more
Every banker should know by now that the Department of Justice announced an “Anti-Redlining” crusade in October 2021. In his October 2021, press release, Attorney General Merrick Garland, proclaimed that redlining is...more
For the last two years, the federal regulatory agencies have been waging a war on redlining by mortgage lenders — a war that shows no signs of abating. Originally published in Law360 - December 12, 2023....more
There has been much understandable handwringing about the new CRA and its complexity as well as the high CRA exam failure rate predicted by regulators based on the new assessment areas and the higher performance standards...more
As I write this article the Department of Justice is pursuing a record-breaking number of “redlining” cases against banks and mortgage lenders. The “Anti-redlining Initiative” was announced October 22, 2021, by Attorney...more
Recently the U.S. Department of Justice (DOJ) entered into a proposed consent order with Ameris Bank to resolve allegations of redlining from 2016 through 2021 in majority Black and Hispanic areas in the Bank’s Jacksonville,...more
On October 19, 2023, the Department of Justice (DOJ) announced that its Combating Redlining Initiative has resulted in over $107 million in relief for communities adversely affected by lending discrimination by mortgage...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
On February 3, the U.S. District Court for the Northern District of Illinois dismissed with prejudice claims that a Chicago-based nonbank mortgage company and its owner violated ECOA by engaging in discriminatory marketing...more
The Justice Department announced that it has entered into an agreement with Lakeland Bank to settle the DOJ’s claims that Lakeland engaged in unlawful redlining in the Newark, New Jersey metropolitan area. The DOJ’s lawsuit...more
At the beginning of his term, President Biden declared that his administration would make it a policy to eliminate “racial bias and other forms of discrimination in all states of home-buying and renting.”...more
The U.S. Department of Justice announced last Thursday that it had reached an agreement with First Merchants Bank, an Indiana state-chartered bank, to settle the redlining lawsuit that the DOJ filed against the bank on June...more