Published 2026-10-12
CFPB's 2025 Fair Lending Report Chronicles Major Shift in Fair Lending Examination, Supervision, and Enforcement
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The CFPB's 2025 Fair Lending Report describes a major program overhaul: the agency says it has stopped using disparate-impact theory, narrowed Special Purpose Credit Program eligibility, prioritized addressing alleged 'debanking,' and revised the §1071 small business lending rule to reduce scope and compliance burdens for many institutions.
Review compliance, underwriting, and reporting processes to assess how narrowed disparate-impact enforcement and the §1071 rule changes could affect your fair-lending exposure and data-collection obligations.
Consider: Which specific underwriting policies and data-collection workflows will you audit first to align with the CFPB’s narrowed disparate-impact stance and the May 2026 §1071 final rule changes?
