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ARTICLE · 08 NOVEMBER 2026

Fair Lending Groups Challenge CFPB’s Regulation B Amendments

Goodwin Procter LLP
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The National Urban League and Massachusetts Association of Community Development Corporations have filed a lawsuit challenging the CFPB's April 2026 amendments to Regulation B, which implements the Equal Credit Opportunity Act. The complaint alleges the amendments unlawfully eliminate disparate-impact liability, narrow discouragement prohibitions, and impose new restrictions on special purpose credit programs offered by for-profit creditors.

United StatesConsumer Protection
Justine McCarthy Potter
Justine McCarthy Potter

In October 2026, the National Urban League and the Massachusetts Association of Community Development Corporations filed suit in the U.S. District Court for the District of Massachusetts challenging the Consumer Financial Protection Bureau’s April 2026 amendments to Regulation B, which implements the Equal Credit Opportunity Act (ECOA). The final rule, which became effective July 21, 2026, provides that ECOA does not authorize disparate-impact liability, narrows Regulation B’s prohibition on discouraging prospective applicants, and imposes new restrictions on special purpose credit programs (SPCPs) offered by for-profit creditors.

The complaint challenges each of these changes and contends that the CFPB acted unlawfully in adopting the rule. Among other things, the plaintiffs allege that the rule conflicts with ECOA and violates the Administrative Procedure Act, that the agency failed adequately to address comments and longstanding reliance interests, and that the CFPB’s acting

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