American Financial Services Association

AFSA Comments on Equal Credit Opportunity Act

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AFSA Comments on Equal Credit Opportunity Act

This week, AFSA responded to the Consumer Financial Protection Bureau’s (CFPB) request for information (RFI) on identifying ways to prevent credit discrimination under the Equal Credit Opportunity Act (ECOA) and expand access to credit for underserved communities. The association’s letter explained, “AFSA and its members support the Bureau in its mission to create a regulatory environment that expands access to credit, helps to ensure that all consumers and communities are protected from discrimination in all aspects of a credit transaction, and develops approaches to address regulatory compliance challenges.”

AFSA submitted answers to the CFPB’s specific questions related to the agency’s approach to analyzing disparate impact, facilitating the use of Special Purpose Credit Programs, providing guidance for creditors using AI/ML techniques, addressing potential conflicts between state laws and the ECOA, along with responses to other questions pertaining to the CFPB’s efforts in addressing credit discrimination under the ECOA.

“AFSA and its members have long supported ECOA’s purpose and strongly oppose all unlawful discrimination, in any form, in any aspect of lending,” AFSA wrote. “In fact, our association’s mission statement emphasizes that one of AFSA’s main goals is promoting ethical lending, and its members employ diverse workforces serving diverse customers.”

December 4th, 2020 by