Credit Discrimination Law

Withdrawn by 90 Fed. Reg. 20,084 (May 12, 2025).

Withdrawn by 90 Fed. Reg. 20,084 (May 12, 2025).

Withdrawn by 90 Fed. Reg. 20,084 (May 12, 2025).

Withdrawn by 90 Fed. Reg. 20,084 (May 12, 2025).

This is a November 14, 2014, letter from a number of consumer groups and law firms representing consumers to the Director of FHFA concerning the fact that that Fannie Mae’s and Freddie Mac’s then current guidelines regarding the treatment of credit reporting disputes impinges on the rights of consumers under the Equal Credit Opportunity Act (ECOA). More importantly, lenders who reject applicants because of disputed tradelines because they are unwilling to manually underwrite the loan appear to be directly violating the ECOA.

Description: This CFPB circular states that creditors may not rely on the checklist of reasons provided in the sample forms (currently codified in Regulation B) to satisfy their obligations under ECOA if those reasons do not

specifically and accurately indicate the principal reason(s) for the adverse action. Nor, as a general matter, may creditors rely on overly broad or vague reasons to the extent that they obscure the specific and accurate reasons relied upon.