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American Financial Services Association

September White Paper | Disparate Impact

September White Paper | Disparate Impact

AFSA’s State Government Affairs September white paper looks at the state legislative landscape on disparate impact liability in lending. As federal agencies pull back on disparate impact enforcement, states such as Illinois and New Jersey have moved to preserve or strengthen it, while similar efforts in Delaware stalled and New York reminded lenders that state fair lending law still applies.

This paper, along with SGA’s other white papers, can be found in the SGA resources section of AFSA’s website.

September 3rd, 2026

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