On April 22, 2026, the Consumer Financial Protection Bureau (CFPB or Bureau) published a sweeping Final Rule amending Subpart A of Regulation B, which implements the Equal Credit Opportunity Act (ECOA).

ECOA broadly prohibits discrimination in any aspect of a credit transaction on the basis of race, color, religion, national origin, sex or marital status, age (provided the applicant has the capacity to contract), receipt of public assistance income, or the good-faith exercise of rights under the Consumer Credit Protection Act. The Consumer Credit Protection Act is an umbrella that includes, among other laws, the Truth in Lending Act, the Fair Credit Reporting Act, the Fair Debt Collection Practices Act, the Fair Credit Billing Act, the Consumer Leasing Act, and the Electronic Fund Transfer Act.

In November 2025, the CFPB issued a notice of proposed rulemaking. The Final Rule adopts the proposal substantially as written, rejecting many of the proposal’s substantive objections.

Link to Click here to read the full GT Alert. Click here to read the full GT Alert.

Photo of Tarrian L. Ellis Tarrian L. Ellis

Tarrian L. Ellis focuses his practice on federal and state regulation of consumer financial products and services, including matters related to fair lending, residential mortgage lending and servicing, student loan servicing, electronic lending, and digital payments. He also advises clients on matters involving…

Tarrian L. Ellis focuses his practice on federal and state regulation of consumer financial products and services, including matters related to fair lending, residential mortgage lending and servicing, student loan servicing, electronic lending, and digital payments. He also advises clients on matters involving the Consumer Financial Protection Bureau (CFPB) and other federal and state regulatory authorities with oversight of consumer financial payments, products, and services.

Prior to joining Greenberg Traurig, he served as a regulatory attorney with the Consumer Financial Protection Bureau in the Office of Regulations. In this role, he participated in complex rulemaking projects, including drafting rules and guidance related to privacy and small business lending, and provided subject matter expertise on issues concerning mortgage servicing and disclosure, and electronic payments.

Photo of Noah Gillespie Noah Gillespie

Noah N. Gillespie is a thought leader who helps financial institutions, payment processors, money services businesses, and fintech companies bring innovative consumer financial products and services to market. He advises clients on federal and state consumer compliance, licensing, and regulatory requirements across the…

Noah N. Gillespie is a thought leader who helps financial institutions, payment processors, money services businesses, and fintech companies bring innovative consumer financial products and services to market. He advises clients on federal and state consumer compliance, licensing, and regulatory requirements across the banking, payments, and digital finance sectors. He provides practical, focused advice that translates complex statutory and regulatory requirements into actionable operational direction.

Photo of Lisa M. Lanham Lisa M. Lanham

Lisa M. Lanham focuses her practice on fintech and payments solutions within the financial services sector. Her role encompasses work with a diverse range of clients, including residential and commercial mortgage brokers, lenders, servicers, loan fulfilment providers, student, consumer, and solar loan lenders

Lisa M. Lanham focuses her practice on fintech and payments solutions within the financial services sector. Her role encompasses work with a diverse range of clients, including residential and commercial mortgage brokers, lenders, servicers, loan fulfilment providers, student, consumer, and solar loan lenders and servicers, marketplace lenders, and entities offering retail installment contracts for consumer goods. Moreover, she advises investors engaged in secondary market activities. Lisa also extends her support to emerging fintech firms, helping them to comply with necessary state licensing requirements and develop products in these realms while keeping regulatory demands in check.

A large part of Lisa’s role involves working closely with regulators such as the New York State Department of Financial Services to facilitate her clients’ pursuit of necessary business licenses and approvals. This not only includes completing audits and examinations but also covering intricate disclosure issues and reporting changes of ownership, executive management, and qualifying individuals. In addition to these tasks, Lisa was involved in the development of the Nationwide Multistate Licensing System & Registry (NMLS) 2.0 system. She handles virtually all aspects of the NMLS, including submissions and amendments of company application forms and electronic surety bonds.

Her contributions extend to representation and regulatory counsel in areas such as structured finance, securitization, secondary market transactions, licensing matters in mergers and acquisitions transactions, regulatory agency coordination for large-scale multistate transactions, and various financial service operations. In addressing state licensing matters, Lisa has contributed to notable projects such as assisting international crypto exchanges enter into the U.S. market by setting up compliant subsidiaries.

Lisa’s work also includes the reporting of material licensing changes, providing technical reviews, analyzing proposed business models in the context of regulatory compliance issues, assisting with the development of policies and procedures for regulatory compliance concerns, negotiating findings before examination report finalization, and managing international licensing issues amidst dynamic regulatory environment.

Photo of Shane Foster Shane Foster

Shane Foster is a shareholder with deep financial regulatory experience in areas such as banking, money transmission, lending, and fintech, among others. Serving in a high-level capacity as Chief Deputy Director at the Arizona Department of Insurance and Financial Institutions (DIFI), he oversaw

Shane Foster is a shareholder with deep financial regulatory experience in areas such as banking, money transmission, lending, and fintech, among others. Serving in a high-level capacity as Chief Deputy Director at the Arizona Department of Insurance and Financial Institutions (DIFI), he oversaw the agency’s enforcement, depository, non-depository, consumer affairs, and insurance market conduct divisions.

As a former regulator, Shane has a thorough understanding of regulatory issues affecting the financial services sector and has deep experience in licensing, compliance, investigatory, and enforcement matters. From advising on chartering de novo depository institutions, merger activity, solvency and deposit insurance issues, to ensuring compliance with consumer protection and safety and soundness regulations, he provides financial institutions with insights to navigate complex issues. Additionally, his experience encompasses various consumer finance segments such as mortgage, vehicle title, and unsecured lending. Shane also led the efforts in drafting and implementing Arizona’s money transmission law (i.e., CSBS Model Money Transmission Modernization Act), which substantive provisions can be found in many states throughout the country.

Shane’s practice extends to the use of new technologies and innovation in the financial services sector. He served a prominent role in the administration of the nation’s first state regulatory sandbox, bolstering his deep understanding of the use of novel products and services in the ever evolving fintech sector (e.g., blockchain technology, digital payments, APIs, artificial intelligence, and mobile applications, among others). Shane also stays at the forefront of law and policy developments regarding digital assets. Whether dealing with transmission and custody issues or monitoring recent guidelines by federal agencies concerning crypto-related activities and stablecoins, Shane stays abreast of developments to advise clients on innovative legal strategies.

Shane has worked closely with state regulators through active involvement in the Conference of State Bank Supervisors (CSBS), National Association of Insurance Commissioners (NAIC), and the National Association of Attorneys General (NAAG), serving as a key participant in numerous multistate initiatives, including serving on the coordinating committee with the Consumer Financial Protection Bureau (CFPB) and on data privacy working groups, among others. Simultaneously, his background in government relations has given him many opportunities to interface with various federal agencies and draft comments on proposed federal policies.

Shane Foster is a sought-after speaker on a variety of topics concerning financial regulation, having spoken on numerous panels at industry and government-related events.