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CFPB and DOJ Withdraw 2023 Guidance on Immigration Status in Credit Decisions

Officials frame the step as a return to statute-based interpretation to reduce lender confusion.

Overview

  • The agencies rescinded an October 12, 2023 joint statement that warned lenders about immigration or citizenship-based policies under ECOA and Regulation B.
  • The withdrawal emphasizes avoiding conflict with the express language of ECOA and its implementing Regulation B.
  • The announcement clarifies that creditors may consider immigration or citizenship status when pertinent to creditworthiness, risk management, other legal requirements, or protecting creditor rights.
  • Officials said the change avoids implying liability under 42 U.S.C. § 1981 beyond what courts have recognized.
  • Acting CFPB Director Russell Vought and DOJ Civil Rights Division leader Harmeet K. Dhillon said the step clarifies fair-lending expectations without adding new compliance burdens.