USA — CFPB (ECOA / Reg B) · USA (consumer credit) · Law
This page is a plain-English summary written by us, not legal advice — the official text is linked above. Our catalogue was last reviewed 2026-08-15; that is a review of the whole catalogue, not an independent legal verification of this entry.
In force. Creditors must give the specific principal reasons for adverse action — "the model is too complex to explain" is not a defense. (CFPB AI adverse-action circulars 2022-03/2023-03 were rescinded May 2025, but the statutory duty is unchanged.)
Give applicants the specific principal reasons for any adverse credit decision — accurate, specific reason codes are required regardless of model complexity (AI/ML included).
Do not discriminate on prohibited bases. Note: the CFPB removed the ECOA disparate-impact "effects test" (Reg B rule eff. 21 Jul 2026), but disparate impact remains live under the Fair Housing Act, DOJ and state law — retain fair-lending testing.
The CFPB removed the ECOA "effects test" — but disparate impact remains actionable under the Fair Housing Act, DOJ and state law, and the rule faces litigation.
Action: Keep fair-lending disparate-impact testing; treat ECOA disparate impact as contested / jurisdiction-dependent, not eliminated.
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