Fair Lending

On October 27, 2026, the CFPB sent Congress its Semi-Annual Report for January through June 2026. The fair lending chapter is short and blunt. The Bureau now pursues "direct evidence of intentional discrimination on a prohibited basis and identified victims," it cited no fair lending violations in the period, and it made no pattern-or-practice referrals to the Department of Justice. This article reads the full report (PDF) for what changed, what did not, and what a fair lending, HMDA or Community Reinvestment Act program should keep doing. Key takeaways The CFPB says it will bring fair lending cases only on intentional discrimination with identified victims, and it will not pursue redlining "based solely on statistical correlation." For banks and credit unions with $10 billion or less…

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Two lawsuits now ask federal judges to throw out the CFPB's April 2026 amendments to Regulation B, the rule that implements the Equal Credit Opportunity Act. The amendments drop the "effects test" for disparate impact, narrow what counts as discouraging an applicant, and restrict how for-profit lenders can run special purpose credit programs. They took effect on July 21, 2026, and no court has paused them. This article covers what the rule changed, who sued and what they want, which fair lending obligations the case does not touch, and which monitoring a fair lending program should keep running while it waits. Everything below is read from the final rule, the complaints and the coverage linked in each paragraph. None of it is legal advice, and we make no guess about how either case will…

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California's Fair Lending Examination Act (AB 801, Chapter 871 of 2026) requires the Department of Financial Protection and Innovation to examine state-chartered banks and credit unions that meet HMDA's loan-volume test, and every residential mortgage lender and servicer licensee, for compliance with federal and California anti-discrimination law in mortgage lending. Banks and credit unions get an exam at least once every four years. Licensees get it inside their existing exam, which must happen at least every 48 months. Governor Newsom approved the bill on September 30, 2026. It is a non-urgency statute with no operative date of its own, so under Article IV, Section 8(c)(1) of the California Constitution it takes effect on January 1, 2027. Everything below is read from the chaptered…

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A fair lending regression tests whether a gap in a lending outcome, such as denial or the rate paid, between a prohibited basis group and a control group survives once the credit factors your policy actually uses are held constant. What survives is the part you will be asked to explain, and the model shows which applications drive it. This article covers the working side of that: what goes into the model, how to read what comes out, and how examiners use the result. It is the companion to what regression can and cannot prove in fair lending, which deals with the method's limits in detail, quoting the OCC's handbook. If you have not read that one, the short version is that a model can only account for the factors you give it. What is a fair lending regression actually testing? Two…

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Every fair lending and CRA software evaluation starts the same way: a shortlist of vendors, a run of demos that all look competent, and a decision that has to be defended internally on something firmer than which interface felt nicer. The difficulty is that the differences between these products are mostly invisible in a demo. They show up eighteen months later, in an examination, when someone asks how a number was produced and the honest answer turns out to be that nobody knows. This is a guide to testing for that in advance. It is written from our side of the table — we sell one of these products — so treat the last section as the interested party it is. The first six are the questions we would ask any vendor in this category, including ourselves. What does fair lending…

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