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ARTICLE · 19 NOVEMBER 2025

CFPB Proposes Material Changes To Equal Credit Opportunity Act Regulations

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On November 13, 2025, the Consumer Financial Protection Bureau (CFPB) released two proposed rules that would materially modify Regulation B and fair lending supervision and enforcement generally.

United StatesConsumer Protection
Andrew Owens
Andrew Owens
Benjamin Saul
Benjamin Saul
Vito Arethusa
Vito Arethusa
Nathaniel Sans
Nathaniel Sans

On November 13, 2025, the Consumer Financial Protection Bureau (CFPB) released two proposed rules that would materially modify Regulation B and fair lending supervision and enforcement generally. Comments on both proposed rules are due by December 13, 2025. Steptoe's Financial Innovation and Regulation group stands ready to assist with answering any questions or to discuss submitting a comment.

Brief Summary

Disparate Impact Proposal. The first rule would narrow certain of Regulation B's restrictions on disparate impact. Specifically, the CFPB would modify Regulation B to: (1) provide that the Equal Credit Opportunity Act (ECOA) does not authorize disparate-impact liability; (2) clarify the scope of "discouragement;" and (3) revise certain requirements applicable to special purpose credit programs (SPCPs).

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