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Racial Equity and Fair Lending at the Forefront of Consumer Financial Services Enforcement

USA - April 30 2021 The Biden administration has moved quickly on its promise to take a more aggressive approach to pursuing actions against consumer financial services…

Joseph L. Barloon, Darren M. Welch

Fair Lending Enforcement Poised To Increase Under Biden Administration

USA - January 26 2021 Administrative enforcement and litigation directed toward the consumer financial services industry is expected to increase under the Biden…

Austin K. Brown, Darren M. Welch

The Impact of Executive Order 13924 and Its Implementing OMB Memorandum on Administrative Enforcement

USA - December 1 2020 In late August 2020, to little notice, the Office of Management and Budget issued a memorandum (the OMB Memorandum) that is likely to have significant…

Austin K. Brown, Darren M. Welch

New UDAAP Guidance Is Relevant to OCC-Regulated and Nonregulated Institutions Alike

USA - September 25 2020 In late June 2020, the Office of the Comptroller of the Currency issued a new booklet on “Unfair or Deceptive Acts or Practices and Unfair, Deceptive…

Austin K. Brown, Darren M. Welch

Special Purpose Credit Programs — Taking a Second Look at a Familiar Tool

USA - July 29 2020 Increasingly, lenders are interested in pursuing proactive efforts to increase lending opportunities for members of African-American, Hispanic and…

Austin K. Brown, Darren M. Welch