Comment Letter: Notice of Proposed Rulemaking on the Equal Credit Opportunity Act

The Trump Administration’s Consumer Financial Protection Bureau (CFPB) has proposed a major rule change that would defang key elements of the 1974 Equal Credit Opportunity Act (ECOA). ECOA, a landmark law that outlaws lending discrimination in credit markets, including on the basis of gender and race, is essential for ensuring everyone has the opportunity to access the credit to buy homes, start a small business, and build wealth.

Notably, the CFPB gave an unusually short 30-day window (with a major federal holiday in the middle) for public input on this proposal. In our comments, we said:

“Woodstock Institute’s work focuses on the areas of consumer financial protection and community economic development. ECOA is a foundational component of that work, including the law’s treatment of disparate impact analysis, prohibited discouragement of applicants, and the implementation of special purpose credit programs. This proposed rule would raise the standard for violations of the law to such an extreme degree that it would counter the legislative intent of the law.”

Read our full comment letter, including a detailed breakdown of the rule’s impact on the 3 areas outlined in the quote above, here. We have also released a statement on this proposal that can be read here.

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Comment Letter: Notice of Proposed Rulemaking on Small Business Lending Under the Equal Credit Opportunity Act (Regulation B)
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