Fair Lending
Fair Lending Self-Assessment: A Step-by-Step Guide for 2026
Updated October 20, 2026: new section on the CFPB's 2025 fair lending report. Fair lending compliance is not only about passing your next exam. It is about being able to show that your institution treats every applicant consistently, and being able to show it with evidence you generated yourself rather than evidence an examiner generated for you. A thorough self-assessment identifies potential issues before examiners do, demonstrates proactive risk management, and protects the institution from enforcement actions that begin as findings nobody looked for. This guide walks through a comprehensive fair lending self-assessment using the same methodology regulators use when they examine an institution. The ten steps are in the order an examiner would work through them, which is also the…
CFPB takes action against Nationstar Mortgage for flawed mortgage loan reporting
Bureau's $1.75 Million Civil Penalty for Persistent and Substantial Reporting Errors is the CFPB's Largest Penalty to Date for HMDA Violations WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB) today ordered Nationstar Mortgage LLC to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (HMDA) by consistently failing to report accurate data about mortgage transactions for 2012 through 2014. Today's action is the largest HMDA civil penalty imposed by the Bureau to date, which stems from Nationstar's market size, the substantial magnitude of its errors, and its history of previous violations. In fact, Nationstar had been on notice since 2011 of HMDA compliance problems. In addition to paying the civil penalty, Nationstar must take the…
CFPB Takes Action Against Fifth Third Bank for Auto-Lending Discrimination and Illegal Credit Card Practices
Company to Pay $18 Million to Minority Auto Borrowers, $3 Million to Credit Card Customers
WASHINGTON, D.C. – Today the Consumer Financial Protection Bureau (CFPB) announced two separate actions against Fifth Third Bank, for discriminatory auto loan pricing and for illegal credit card practices. The joint CFPB and Department of Justice (DOJ) auto-lending enforcement action requires Fifth Third to change its pricing and compensation system to minimize the risks of discrimination, and to pay $18 million to harmed African-American and Hispanic borrowers. The CFPB's action against Fifth Third's deceptive marketing of credit card add-on products requires the bank to provide an estimated $3 million in relief to eligible harmed consumers and pay a $500,000 penalty.
| Institution | Regulator(s) | Violation | Penalty | Period covered | HMDA/fair-lending data field involved |
|---|---|---|---|---|---|
| Fifth Third Bank | CFPB, DOJ | Discriminatory auto loan pricing — violated the Equal Credit Opportunity Act by charging African-American and Hispanic borrowers higher dealer markups than non-Hispanic white borrowers, without regard to creditworthiness | $18 million to harmed African-American and Hispanic borrowers ($12 million into a settlement fund, plus credit of $5–$6 million for remediation already provided, with any additional funds paid in to reach $18 million total); no penalty assessed for this action | January 2010 through September 2015 | Dealer markup on auto loan interest rate (race and national origin) |
| Fifth Third Bank | CFPB | Deceptive marketing and sales of "Debt Protection" credit card add-on product, in violation of the Dodd-Frank Act | $3 million in relief to roughly 24,500 customers, plus a $500,000 penalty to the CFPB civil penalty fund | 2007 through February 2013 (fulfillment kit misrepresentations from December 2011 through September 2012) | — |
Justice Department and Consumer Financial Protection Bureau Reach Settlement with Hudson City Savings Bank to Resolve Allegations of Mortgage Lending
Settlement Provides Over $27 Million to Ensure Equal Lending Services to Predominantly Black and Hispanic Communities
The Justice Department and Consumer Financial Protection Bureau (CFPB) filed a consent order today to resolve allegations that Hudson City Savings Bank (Hudson City) engaged in a pattern or practice of "redlining" predominantly Black and Hispanic neighborhoods in its residential mortgage lending practices. "Redlining" is the discriminatory practice by banks or other financial institutions to deny or avoid providing credit services to a consumer because of the racial demographics of the neighborhood in which the consumer lives. This resolution represents the Justice Department's largest residential mortgage redlining settlement in its history.
| Institution | Regulator(s) | Violation | Penalty | Period covered | HMDA/fair-lending data field involved |
|---|---|---|---|---|---|
| Hudson City Savings Bank | Justice Department; Consumer Financial Protection Bureau (CFPB) | Redlining predominantly Black and Hispanic neighborhoods in residential mortgage lending, in violation of the Fair Housing Act and Equal Credit Opportunity Act (ECOA) | $25 million loan subsidy fund; $2.25 million for advertising, outreach, financial education, and community partnership efforts; two new full-service branches; $5.5 million civil monetary penalty (total over $27 million) | At least 2009 to 2013 | — |
CFPB Orders RPM Mortgage to Pay $19 Million for Steering Consumers Into Costlier Mortgages
RPM CEO Erwin Robert Hirt to Pay Additional $1 Million Civil Penalty
WASHINGTON, D.C. – Today, the Consumer Financial Protection Bureau (CFPB) filed a complaint in federal district court against RPM Mortgage, Inc. and its CEO, Erwin Robert Hirt, for illegally paying bonuses and higher commissions to loan originators to incentivize them to steer consumers into costlier mortgages. The CFPB also filed a proposed order that, if entered by the court, would require RPM to pay $18 million in redress to consumers and a $1 million civil penalty, and would require Hirt to pay an additional $1 million civil penalty.
| Institution | Regulator(s) | Violation | Penalty | Period covered | HMDA/fair-lending data field involved |
|---|---|---|---|---|---|
| RPM Mortgage, Inc. | Consumer Financial Protection Bureau (CFPB) | Violated the Loan Originator Compensation Rule and the Consumer Financial Protection Act (CFPA) by paying bonuses and higher commissions to loan originators to incentivize them to steer consumers into costlier mortgages | $18 million in redress to consumers; $1 million civil penalty (RPM); Hirt to pay an additional $1 million civil penalty | April 2011 through December 2013 | Loan officer compensation / steering |
- California's New Fair Lending Exam Law: What State-Chartered Banks, Credit Unions and Mortgage Licensees Should Have Ready
- How to Benchmark Your CRA and HMDA Lending Against Peer Data
- HMDA vs CRA vs Section 1071: What Each Rule Collects and Who Has to File
- Fair Lending Regression Analysis: What It Controls For and How to Explain a Pricing Disparity
- 2026 HMDA Data: Your Filing Checklist for the March 1, 2027 Deadline
- HMDA Plus: What It Actually Changed in the LAR Workflow
- How to Fix the 10 Most Common HMDA Edit Check Errors
- CFPB and DOJ Settle Redlining Claims Against Non-Depository Mortgage Companies Before Change in Administration
- How to Evaluate Fair Lending and CRA Software: What to Test Before You Sign
- What a Fair Lending Exam Actually Asks For
- Fair Servicing: What Examiners Test in Servicing Data, and How to Test It First
- What Actually Counts as a Small Business Loan Under Section 1071
- Section 1071 in 2026: What Lenders Need to Know About Small Business Lending Data
