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ARTICLE · 05 NOVEMBER 2026

CFPB Releases Annual Fair Lending Report For 2025

Goodwin Procter LLP
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The Consumer Financial Protection Bureau has released its 2025 Fair Lending Report, documenting a dramatic shift in enforcement priorities and regulatory approach. The report details the agency's abandonment of disparate impact analysis, restrictions on special purpose credit programs, and new focus on preventing debanking based on political or religious beliefs.

United StatesConsumer Protection
Christian Fletcher
Christian Fletcher

On October 1, the Consumer Financial Protection Bureau (CFPB) complied with statutory reporting requirements by releasing the Fair Lending Report of the Consumer Financial Protection Bureau for 2025, the CFPB’s summary of its fair lending work during 2025. The report boasts of a sweeping reorientation of the CFPB’s priorities from the prior administration. Over the reporting period and into 2026, the CFPB has, according to the report, taken the following actions:

  • Abandoned disparate impact as a supervision and enforcement tool. The CFPB closed all open exams and investigations that relied on it, and finalized an amendment to Regulation B removing the “effects test” (the evaluation of whether a creditor’s facially neutral lending policy nevertheless disproportionately harmed a protected group). The CFPB thereby affirmed its view that the Equal Credit Opportunity Act (ECOA) does not authorize disparate impact liability.

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