Industry veteran challenges CFPB’s support of disparate impact
HUD Proposed Rule Demands More Disparate and More impact to Establish Disparate Impact Liability; Stay of Litigation and Compliance Date Continued in Payday Lending Rule Lawsuit; Big Picture Loans Lands Big Win for Tribal Lenders in Sovereign Immunity Case
Is disparate impact applicable Under Fair Housing Act and ECOA? Most lower federal courts have held that the disparate impact theory is applicable. Supreme Court decisions in recent years addressing the application of disparate impact under other, but similar, laws have cast doubt on the correctness of those decisions.
This is a company that not only expanded their overall portfolio via acquisitions, but also proceeded to take the steps to increase their impact in their new domain. The acquisitions were a disparate.
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The Consumer Financial Protection Bureau (CFPB or Bureau) seeks information about the use or potential use of alternative data and modeling techniques in the credit process. Alternative data and modeling techniques are changing the way that some financial service providers conduct business.
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CFPB enforces federal fair lending rules designed to prevent discrimination based on protected demographic characteristics, such as race, religion, or gender. The doctrine of disparate impact, which is used in many fair lending cases, has received considerable attention in recent years. It holds that certain practices are discriminatory and.
MGMT 4890. Employment relationship is a contract: the exchange of labor for compensation Most private-sector employment relationships are "at-will" agreements (more on this in Ch. 2) An employee may choose to work or not to work for a given employer An employer may choose to hire or not to hire a given applicant,
Significant Flaws in the CFPB’s Methodology. First, a broad industry move by finance sources to eliminate dealer discretion through the payment of flat fees will, quite simply, fail to eliminate dealer discretion. This is because dealers typically sell credit contracts to a variety of finance sources.
Following is a deeper look at the CFPB’s use of disparate impact – a legal theory that cites lenders for unintentional discrimination based on statistical analysis of the loan portfolios – against the auto industry, and the agency’s internal debate over how best to curb bias. The CFPB targets auto lenders