John R. Mussman

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The past several months have seen numerous important happenings under fair lending developments, both in the courts, by the DOJ, and by at least one state attorney general. DOJ Blog Posting On August 1, Greg Friel, Deputy Assistant Attorney General for Civil Rights Division, U.S. Department of Justice (DOJ), posted a blog entitled “Protecting Borrowers from Credit Discrimination in All Forms,” The Justice Blog, DOJ Aug. 1, 2014. The blog posting pointed out that…
On April 18, 2012, the Consumer Financial Protection Bureau (the “Bureau”) issued Bulletin 2012-04, announcing its approach to evaluating discrimination under the Equal Credit Opportunity Act (“ECOA”) and its implementing regulation, Regulation B. There were no surprises, as the CFPB reaffirmed the position taken previously in the 1994 Policy Statement on Discrimination in Lending (“Policy Statement”) by 10 federal banking agencies, the FTC, and the Justice Department, and in Regulation B and the Federal Reserve…