CFPB Revised Fair Lending Enforcement Framework Under ECOA

On April 22, the CFPB issued a final rule revising Regulation B under the Equal Credit Opportunity Act (ECOA). The rule eliminates disparate impact liability from the Bureau’s ECOA enforcement framework, narrows standards governing discouragement of prospective applicants, and imposes significant new restrictions on special purpose credit programs (SPCPs) offered by for-profit lenders. The rule will take effect 90 days after publication in the Federal Register.... By: Sheppard, Mullin, Richter & Hampton LLP