Well-Intentioned, but Not Well-Executed
AFSA has submitted a comment letter raising concerns with SB 3777, noting that while well-intentioned, the bill relies on a disparate impact framework that could create significant unintended consequences for the consumer credit system.
For decades the Equal Credit Opportunity Act (ECOA) has provided strong, effective protections against discrimination, supported by clear compliance requirements and meaningful penalties for violations.
AFSA cautioned that introducing ambiguous, subjective standards—particularly through a disparate impact approach—may increase uncertainty, invite claims without clear evidentiary grounding, and disrupt the availability of credit. While supporting the goal of fair and accessible lending, AFSA urged policymakers to pause and further study the proposal to ensure any changes result from careful, evidence-based analysis.
This letter, along with SGA’s other recent letters, can be found on the direct advocacy section of AFSA’s website.
May 28th, 2026
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