CFPB, Federal Agencies, State Agencies, and Attorneys General
The OCC and FDIC announced yesterday that they have extended the 60-day comment period for their joint proposal to revise their regulations implementing the Community Reinvestment Act that was published in the Federal Register on January 8, 2020. As extended by 30 days, the comment period ends on April 8, 2020.
The California Reinvestment Coalition,…
One of the most important areas of consumer financial regulation today is the use of internet- or social media-based platforms to target advertising for consumer financial products. Its importance stems from the fact that financial services companies can obtain significant benefits from directing advertising to those consumers most likely to be interested in a product,…
In this podcast, after reviewing what redlining is, we look at which regulators have made it a focus, factors they consider when looking for redlining, whether those factors apply to nonbanks and how nonbanks can assess and reduce risk. We also discuss emerging theories of digital redlining.
Click here to listen to the podcast.
The House Financial Services Committee has announced that it will hold the following hearings this month:
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Our podcast looks at the proposed changes to HUD’s rule for establishing liability under the FHA for discriminatory practices based on disparate impact even without discriminatory intent. We discuss the proposal’s history, five-part burden-shifting framework, available defenses (looking closely at those for models used to assess credit risk), and HUD’s likely next steps.
In this podcast, we examine the fair lending risk to financial services providers that use targeted marketing. After reviewing what targeted marketing is, the forms it can take, and current litigation, we discuss the potential fair lending claims and the options available to providers to reduce the fair lending risk created by the use of…
On October 29, 2019, the House Financial Services Subcommittee on Oversight and Investigations held a hearing to explore the issue of lending and housing discrimination against members of the LGBTQ+ community. A recording of the hearing is available here.
Six witnesses offered testimony and responded to questions posed by subcommittee members:
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A purported class action filed last week in the U.S. District Court for the Northern District of California, accuses Facebook of discriminating against women and individuals over 40 who were denied advertisements and information about certain financial services opportunities, including those for bank accounts, insurance, and investing.
According to the complaint, Facebook encourages financial…
The CFPB announced today that it will hold a symposium on Dodd-Frank Act Section 1071 on November 6, 2019. Section 1071 amended the ECOA to require financial institutions to collect and report certain data in connection with credit applications made by women- or minority-owned businesses and small businesses. Such data includes the race, sex, and…
In its proposed disparate impact rule published in today’s Federal Register, HUD sets forth a framework for making (and defending against) claims of disparate impact under the Fair Housing Act. In this blog post, we take a closer look at a new and unique aspect of the proposed rule: its treatment of mathematical models…
