Agency Cooperation In Fair Lending Enforcement

Joint investigations, cross-agency partnership, cooperation ... terms all too familiar to regulatory and defense practitioners accustomed to collaboration among the alphabet soup of federal regulators. These terms may now be regularly used to describe the emergent relationship between the Department of Justice (DOJ) and the Consumer Financial Protection Bureau (CFPB). Indeed, the Attorney General's 2014 Annual Report to Congress Pursuant to the Equal Credit Opportunity Act Amendments of 1976, published this month, touts the increased cooperation between these agencies to vigorously enforce federal fair lending laws. One such law, the Equal Credit Opportunity Act (ECOA), prohibits lenders from discriminating against credit applicants on the basis of race, color, religion, age, sex and national origin, among other factors.