State AGs urge Mulvaney to continue use of disparate impact theory of ECOA liability
CFPB Monitor
SEPTEMBER 13, 2018
57, disapproving of the CFPB’s Bulletin 2013-2 regarding “Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act.” As the Supreme Court aptly recognized in Inclusive Communities , limitations on disparate impact liability are necessary to protect potential defendants from abusive disparate impact claims.
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