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CFPB and DOJ Withdraw 2023 Guidance on Immigration Status in Lending

Officials say the move clarifies that ECOA permits lenders to consider lawful residence status when assessing credit risk.

Overview

  • The agencies formally rescinded their October 2023 joint statement that cautioned lenders about immigration-status–based policies under ECOA and Regulation B.
  • Acting CFPB Director Russell Vought said regulations have long allowed consideration of a borrower’s lawful residence status to protect creditor rights and repayment.
  • DOJ Civil Rights Division head Harmeet K. Dhillon said the step restores alignment with established civil rights law and criticized the prior guidance as ideologically driven.
  • The withdrawal cites concerns about confusion, misimpressions regarding 42 U.S.C. § 1981, and unnecessary compliance burdens, while affirming lenders may weigh status to manage risk or meet other legal obligations.
  • Legal practitioners and former officials say the change could curb noncitizens’ access to credit and encourage blunt rules such as active Social Security number requirements, though ECOA’s anti-discrimination protections remain in force.