An increasing amount of cutting-edge litigation is challenging predatory lending practices as violations of federal and state civil rights and credit discrimination
statutes, including the Fair Housing Act and the Equal Credit Opportunity Act.
Each year these organizations together receive over a thousand complaints of alleged credit discrimination
The retention of these records is intended to allow the systematic review and analysis of creditors' possible use of race, age, national origin, and other prohibited bases of credit discrimination
in connection with prescreened solicitations.
Culhane, the current chairman of the American Bar Association subcommittee that covers credit discrimination
issues, frequently speaks and writes about financial institution issues and has published articles in The Business Lawyer, Commercial Lending Review, BNA Lender Liability Report, CFI Compliance News and ABA Bank Compliance.
This makes detecting illegal credit discrimination
in small business lending far more difficult than for mortgage credit.
This person will help coordinate our efforts in this area and assist our examiners in analyzing the complex issues associated with detection of credit discrimination
In the meantime, the Federal Reserve has referred ten complaints that allege mortgage credit discrimination
to the Department of Housing and Urban Development under an interagency cooperation agreement signed last year.
I appreciate the opportunity to speak today to this committee about concerns related to credit discrimination
in mortgage lending.