[Federal Register Volume 85, Number 149 (Monday, August 3, 2020)]
[Notices]
[Pages 46600-46603]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-16722]



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BUREAU OF CONSUMER FINANCIAL PROTECTION

[Docket No. CFPB-2020-0026]


Request for Information on the Equal Credit Opportunity Act and 
Regulation B

AGENCY: Bureau of Consumer Financial Protection.

ACTION: Notice and request for information.

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SUMMARY: The Bureau of Consumer Financial Protection (Bureau) seeks 
comments and information to identify opportunities to prevent credit 
discrimination, encourage responsible innovation, promote fair, 
equitable, and nondiscriminatory access to credit, address potential 
regulatory uncertainty, and develop viable solutions to regulatory 
compliance challenges under the Equal Credit Opportunity Act (ECOA) and 
Regulation B.

DATES: Comments must be received by October 2, 2020.

ADDRESSES: You may submit responsive information and other comments, 
identified by Docket No. CFPB-2020-0026, by any of the following 
methods:
     Federal eRulemaking Portal: Go to http://www.regulations.gov. Follow the instructions for submitting comments.
     Email: [email protected]. Include Docket No. CFPB-
2020-0026 in the subject line of the message.
     Mail/Hand Delivery/Courier: Comment Intake, Bureau of 
Consumer Financial Protection, 1700 G Street NW, Washington, DC 20552. 
Please note that due to circumstances associated with the COVID-19 
pandemic, the Bureau discourages the submission of comments by mail, 
hand delivery, or courier.
     Instructions: The Bureau encourages the early submission 
of comments. All submissions must include the document title and docket 
number. Because paper mail in the Washington, DC area and at the Bureau 
is subject to delay, and in light of difficulties associated with mail 
and hand deliveries during the COVID-19 pandemic, commenters are 
encouraged to submit comments electronically. In general, all comments 
received will be posted without change to http://www.regulations.gov. 
In addition, once the Bureau's headquarters reopens, comments will be 
available for public inspection and copying at 1700 G Street NW, 
Washington, DC 20552, on official business days between the hours of 10 
a.m. and 5 p.m. Eastern Time. At that time, you can make an appointment 
to inspect the documents by telephoning 202-435-9169.
    All submissions in response to this request for information (RFI), 
including attachments and other supporting materials, will become part 
of the public record and subject to public disclosure. Please do not 
include in your submissions sensitive personal information, such as 
account numbers or Social Security numbers, or names of other 
individuals, or other information that you would not ordinarily make 
public, such as trade secrets or confidential commercial information. 
Submissions will not be edited to remove any identifying or contact 
information, or other information that you would not ordinarily make 
public. If you wish to submit trade secret or confidential commercial 
information, please contact the individuals listed in the FOR FURTHER 
INFORMATION CONTACT section below. Information submitted to the Bureau 
will be treated in accordance with the Bureau's Rule on the Disclosure 
of Records and Information, 12 CFR part 1070 et seq.

FOR FURTHER INFORMATION CONTACT: For general inquiries and submission 
process questions, please call Pavy Bacon, Senior Counsel, Office of 
Regulations at 202-435-7700. If you require this document in an 
alternative electronic format, please contact 
[email protected].

SUPPLEMENTARY INFORMATION: 

I. Background

    The Dodd-Frank Wall Street Reform and Consumer Protection Act 
(Dodd-Frank Act) \1\ granted primary authority to the Bureau to 
supervise and enforce compliance with ECOA and its implementing 
regulation, Regulation B, for entities within Bureau's jurisdiction and 
to issue regulations and guidance to interpret ECOA. The Dodd-Frank Act 
requires the Bureau to report on its efforts ``to fulfill the fair 
lending mission of the Bureau,'' \2\ and authorizes it to ``engage in . 
. . requests for information, [which] includes matters relating to fair 
lending.'' \3\
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    \1\ Public Law 111-203, 124 Stat. 1376 (2010).
    \2\ 12 U.S.C. 5496(c)(8).
    \3\ 12 U.S.C. 5562(a)(2).
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    The Dodd-Frank Act clearly states the Bureau's purpose as follows: 
``to implement and, where applicable, enforce Federal consumer 
financial law consistently for the purpose of ensuring that all 
consumers have access to . . . markets for consumer financial products 
and services are fair, transparent, and competitive.'' \4\ The Bureau's 
mission includes both protecting consumers from unlawful discrimination 
and fostering innovation. Specifically, the Dodd-Frank Act makes clear 
that ``[t]he Bureau is authorized to exercise its authorities under 
[F]ederal consumer financial law for the purposes of ensuring that, 
with respect to consumer financial products and services . . . (2) 
consumers are protected from unfair, deceptive, or abusive acts and 
practices and from discrimination . . . and (5) markets for consumer 
financial products and services operate transparently and efficiently 
to facilitate access and innovation.'' \5\ This RFI is one method by 
which the Bureau is continuing to explore ways to ensure 
nondiscriminatory access to credit as well as cutting-edge issues at 
the intersection of fair lending and innovation, including how 
innovation can increase access to credit for all consumers--and 
especially unbanked and underbanked consumers (referred to as ``credit 
invisibles'' in a May 2015 Bureau research report \6\)--without 
unlawful discrimination.
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    \4\ 12 U.S.C. 5511(a) (emphasis added).
    \5\ 12 U.S.C. 5511(b).
    \6\ See The CFPB Office of Research, Data Point: Credit 
Invisibles (May 2015), https://files.consumerfinance.gov/f/201505_cfpb_data-point-credit-invisibles.pdf.

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    The Equal Credit Opportunity Act (ECOA),\7\ which is implemented by 
Regulation B, applies to creditors. The statute makes it unlawful for 
``any creditor to discriminate against any applicant, with respect to 
any aspect of a credit transaction (1) on the basis of race, color, 
religion, national origin, sex or marital status, or age (provided the 
applicant has the capacity to contract); (2) because all or part of the 
applicant's income derives from any public assistance program; or (3) 
because the applicant has in good faith exercised any right under [the 
Consumer Credit Protection Act].'' \8\ The Bureau has recognized the 
following methods of proving lending discrimination: Overt evidence of 
discrimination, evidence of disparate treatment, and evidence of 
disparate impact.\9\ ECOA prohibits discrimination ``with respect to 
any aspect of a credit transaction.'' \10\ As such, Regulation B covers 
creditor activities before, during, and after the extension of 
credit.\11\ Creditors are also prohibited from making any oral or 
written statement, in advertising or otherwise, to applicants or 
prospective applicants that would discourage, on a prohibited basis, a 
reasonable person from making or pursuing an application.\12\ A 
creditor may affirmatively solicit or encourage members of 
traditionally disadvantaged groups to apply for credit, especially 
groups that might not normally seek credit from that creditor.\13\ 
Creditors may also meet special social needs and benefit economically 
disadvantaged groups through the Special Purpose Credit Program 
provisions of ECOA and Regulation B.\14\
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    \7\ 15 U.S.C. 1691 et seq.
    \8\ 15 U.S.C. 1691(a).
    \9\ See Comment 4(a)-1 (``Disparate treatment on a prohibited 
basis is illegal whether or not it results from a conscious intent 
to discriminate''); Comment 6(a)-2 (``The Act and regulation may 
prohibit a creditor practice that is discriminatory in effect 
because it has a disproportionately negative impact on a prohibited 
basis, even though the creditor has no intent to discriminate and 
the practice appears neutral on its face, unless the creditor 
practice meets a legitimate business need that cannot reasonably be 
achieved as well by means that are less disparate in their 
impact.''); Bureau of Consumer Fin. Prot., Equal Credit Opportunity 
Act (ECOA) Examination Procedures (Oct. 30, 2015), https://files.consumerfinance.gov/f/documents/201510_cfpb_ecoa-narrative-and-procedures.pdf; see also CFPB Bulletin 2012-04 (Fair Lending), 
Lending Discrimination (Apr. 18, 2012), https://files.consumerfinance.gov/f/201404_cfpb_bulletin_lending_discrimination.pdf (concurring with 
Interagency Task Force on Fair Lending, Policy Statement on 
Discrimination in Lending, 59 FR 18266 (Apr. 15, 1994) (noting that 
``courts have recognized three methods of proof of lending 
discrimination under the ECOA . . .: [(1)] `Overt evidence of 
discrimination,' when a lender blatantly discriminates on a 
prohibited basis; [(2)] Evidence of `disparate treatment,' when a 
lender treats applicants differently based on one of the prohibited 
factors; and [(3)] Evidence of `disparate impact,' when a lender 
applies a practice uniformly to all applicants but the practice has 
a discriminatory effect on a prohibited basis and is not justified 
by business necessity.'').
    \10\ 15 U.S.C. 1691(a).
    \11\ 12 CFR 1002.4(a). See also Comment 4(a)-1 (providing that 
``1002.4(a) covers all dealings, without exception, between an 
applicant and a creditor, whether or not addressed by other 
provisions of the regulation . . . for example, application 
procedures, criteria used to evaluate creditworthiness, 
administration of accounts, and treatment of delinquent or slow 
accounts'').
    \12\ 12 CFR 1002.4(b).
    \13\ Comment 4(b)-2.
    \14\ See 12 CFR 1002.8.
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II. Request for Information

    The Bureau seeks comments on the actions it can take or should 
consider taking to prevent credit discrimination, encourage responsible 
innovation, promote fair, equitable, and nondiscriminatory access to 
credit, address potential regulatory uncertainty, and develop viable 
solutions to regulatory compliance challenges under ECOA and Regulation 
B. The information provided will help the Bureau identify how it can 
continue to create a regulatory environment that expands access to 
credit, help to ensure that all consumers and communities are protected 
from discrimination in all aspects of a credit transaction, and develop 
approaches to address regulatory compliance challenges. The Bureau 
encourages comments from all interested members of the public. The 
Bureau anticipates that the responding public may include (among 
others) financial entities or institutions and their service providers; 
trade associations that represent these entities; individual consumers; 
fair lending, civil rights, consumer and community advocates; Federal, 
Tribal, State, and local regulators and agencies; researchers or 
members of academia; or attorneys that represent any of the above. The 
Bureau encourages commenters to share their views on all or a subset of 
the questions included in this RFI. These questions are not meant to be 
exhaustive; the Bureau welcomes additional relevant comments on these 
important topics. For answers to specific questions, please note the 
number associated with any question to which you are responding at the 
top of each response.
    In particular, the Bureau requests commenters to respond to the 
following questions:
    1. Disparate Impact: Regulation B provides that ECOA may prohibit 
creditor practices that have a disparate impact--Regulation B 
specifically states that ``Congress intended an `effects test' concept 
. . . to be applicable to a creditor's determination of 
creditworthiness.'' \15\ The official interpretation to Regulation B 
states that ECOA/Regulation B ``may prohibit a creditor practice that 
is discriminatory in effect because it has a disproportionately 
negative impact on a prohibited basis, even though the creditor has no 
intent to discriminate and the practice appears neutral on its face, 
unless the creditor practice meets a legitimate business need that 
cannot reasonably be achieved as well by means that are less disparate 
in their impact.'' \16\ The official interpretation also provides an 
example of how to evaluate a creditor practice for disparate 
impact.\17\ Should the Bureau provide additional clarity regarding its 
approach to disparate impact analysis under ECOA and/or Regulation B? 
If so, in what way(s)?
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    \15\ 12 CFR 1002.6(a).
    \16\ Comment 6(a)-2.
    \17\ Id.
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    2. Limited English Proficiency: The Bureau seeks to foster greater 
access to credit markets, including to consumers who face obstacles 
because they are Limited English Proficient (LEP). The Bureau did some 
work on the challenges LEP consumers encounter in 2016 and 2017.\18\ In 
its continued outreach on these topics, the Bureau has heard from a 
variety of stakeholders that institutions want to serve LEP consumers 
but face regulatory uncertainties and perceived fair lending risks in 
serving LEP consumers because the language spoken by a consumer may 
correlate with prohibited bases under ECOA, including national origin. 
Some financial institutions may decide against providing any LEP 
products or services due to these regulatory uncertainties, while 
others may vary how and when they offer products and services in non-
English languages.
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    \18\ See Bureau of Consumer Fin. Prot., Financial education 
programs serving immigrant populations (July 2016), https://files.consumerfinance.gov/f/documents/20160714_cfpb_report_fined_immigrant_May_20_2016_FINAL.pdf; Bureau 
of Consumer Fin. Prot., Spotlight on serving limited English 
proficient consumers (Nov. 2017), https://files.consumerfinance.gov/f/documents/cfpb_spotlight-serving-lep-consumers_112017.pdf; Bureau 
of Consumer Fin. Prot., Supervisory Highlights (Oct. 2016), https://files.consumerfinance.gov/f/documents/Supervisory_Highlights_Issue_13__Final_10.31.16.pdf.
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    The Bureau seeks to understand the challenges specific to serving 
LEP consumers and to find ways to encourage creditors to increase 
assistance to LEP consumers. Should the Bureau provide additional 
clarity under ECOA and/or Regulation B to further encourage creditors 
to provide

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assistance, products, and services in languages other than English to 
consumers with limited English proficiency? If so, in what way(s)?
    3. Special Purpose Credit Programs: The Special Purpose Credit 
Program (SPCP) provisions of ECOA/Regulation B provide targeted means 
by which creditors, under certain circumstances, can meet ``special 
social needs'' and ``benefit economically disadvantaged groups.'' \19\ 
The official interpretation to Regulation B states that ``a for-profit 
organization must determine that the program will benefit a class of 
people who would otherwise be denied credit or would receive it on less 
favorable terms. This determination can be based on a broad analysis 
using the organization's own research or data from outside sources, 
including governmental reports and studies.'' \20\ ECOA and Regulation 
B also allow for special purpose credit offered under ``[a]ny credit 
assistance program offered by a not-for-profit organization, as defined 
under section 501(c) of the Internal Revenue Code of 1954, as amended, 
for the benefit of its members or for the benefit of an economically 
disadvantaged class of persons.'' \21\ Through stakeholder engagement 
and its supervisory activity, the Bureau has learned that stakeholders 
are interested in additional guidance on SPCPs that may be helpful to 
them in developing SPCPs while ensuring regulatory compliance. In its 
Summer 2016 Supervisory Highlights, the Bureau set forth observations 
regarding credit decisions made pursuant to the terms of programs that 
for-profit institutions have described as SPCPs.\22\
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    \19\ 12 CFR 1002.8(a).
    \20\ Comment 8(a)-5.
    \21\ Comments 9(b)(2)-4, 5.
    \22\ See, e.g., Bureau of Consumer Fin. Prot., Supervisory 
Highlights (June 2016), https://files.consumerfinance.gov/f/documents/Supervisory_Highlights_Issue_12.pdf.
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    Should the Bureau address any potential regulatory uncertainty and 
facilitate the use of SPCPs? If so, in what way(s)? For example, should 
the Bureau clarify any of the SPCP provisions in Regulation B?
    4. Affirmative Advertising to Disadvantaged Groups: The official 
interpretation to Regulation B states that ``[a] creditor may 
affirmatively solicit or encourage members of traditionally 
disadvantaged groups to apply for credit, especially groups that might 
not normally seek credit from that creditor.'' \23\ The Bureau 
understands from its stakeholder engagement that creditors are 
interested in additional guidance that may be helpful to them in 
developing such marketing campaigns while ensuring regulatory 
compliance. Should the Bureau provide clarity under ECOA and/or 
Regulation B to further encourage creditors to use such affirmative 
advertising to reach traditionally disadvantaged consumers and 
communities? If so, in what way(s)?
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    \23\ Comment 4(b)-2.
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    5. Small Business Lending: As the Bureau noted in its May 2017 
white paper on small business lending, small businesses play a key role 
in fostering community development and fueling economic growth both 
nationally and in their local communities.\24\ Women-owned and 
minority-owned small businesses play a particularly important role in 
supporting their local communities.\25\ Access to credit is a crucial 
component of the success of these businesses. ECOA and Regulation B 
protect business owners from discrimination because of race, color, 
national origin, sex, and other protected characteristics.\26\ In light 
of the Bureau's authority under ECOA/Regulation B, in what way(s) might 
it support efforts to meet the credit needs of small businesses, 
particularly those that are minority-owned and women-owned?
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    \24\ Bureau of Consumer Fin. Prot., Key dimensions of the small 
business lending landscape (May 2017), https://files.consumerfinance.gov/f/documents/201705_cfpb_Key-Dimensions-Small-Business-Lending-Landscape.pdf.
    \25\ Id.
    \26\ 15 U.S.C. 1691(a); 12 CFR 1002.4(a).
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    6. Sexual Orientation and Gender Identity Discrimination: On June 
15, 2020, in Bostock v. Clayton County, the Supreme Court ruled that 
the prohibition against sex discrimination in Title VII of the Civil 
Rights Act of 1964 (Title VII) encompasses sexual orientation 
discrimination and gender identity discrimination.\27\ The majority 
opinion in Bostock interpreted Title VII and did not address ECOA. 
Should the Supreme Court's decision in Bostock affect how the Bureau 
interprets ECOA's prohibition of discrimination on the basis of sex? If 
so, in what way(s)?
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    \27\ 590 U.S. , 140 S. Ct. 1731 (2020) (Bostock).
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    7. Scope of Federal Preemption of State Law: Regulation B alters, 
affects, or preempts only those state laws that are inconsistent with 
ECOA and/or Regulation B and then only to the extent of the 
inconsistency.\28\ A state law is not inconsistent with ECOA or 
Regulation B if it is more protective of an applicant.\29\ A creditor, 
state, or other interested party may request that the Bureau determine 
whether a state law is inconsistent with the requirements of ECOA and/
or Regulation B.\30\ What are examples of potential conflicts or 
intersections between state laws, state regulations, and ECOA and/or 
Regulation B, and should the Bureau address such potential conflicts or 
intersections? For example, should the Bureau provide further guidance 
to assist creditors evaluating whether state law is preempted to the 
extent it is inconsistent with the requirements of ECOA and/or 
Regulation B?
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    \28\ 12 CFR 1002.11(a).
    \29\ Id.
    \30\ 12 CFR 1002.11(b)(2).
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    8. Public Assistance Income: ECOA makes it ``unlawful for any 
creditor to discriminate against any applicant, with respect to any 
aspect of a credit transaction . . . because all or part of the 
applicant's income derives from any public assistance program.'' \31\ 
ECOA provides that making an inquiry whether the applicant's income 
derives from any public assistance program does not constitute 
discrimination ``if such inquiry is for the purpose of determining the 
amount and probable continuance of income levels [among other 
things].'' \32\ The official interpretation to Regulation B further 
provides that ``[i]n considering the separate components of an 
applicant's income, the creditor may not automatically discount or 
exclude from consideration any protected income. Any discounting or 
exclusion must be based on the applicant's actual circumstances.'' \33\ 
The Bureau previously issued guidance (through a May 2015 bulletin on 
the Section 8 Housing Choice Voucher Homeownership Program \34\ and a 
November 2014 bulletin on Social Security Disability Income 
Verification \35\) to help creditors comply with these and other 
regulatory provisions. The Bureau understands that stakeholders 
continue to have questions about these provisions under ECOA and/or 
Regulation B.
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    \31\ 15 U.S.C. 1691(a)(2).
    \32\ 15 U.S.C. 1691(b)(2); see also 12 CFR 1002.6(b)(5) (``[A] 
creditor may consider the amount and probable continuance of any 
income in evaluating an applicant's creditworthiness . . . .'').
    \33\ Comment 6(b)(5)-(3)(ii); see also Comment 6(b)(5)-(1) (``A 
creditor must evaluate income derived from . . . public assistance 
on an individual basis . . . .).
    \34\ See CFPB Bulletin 2015-02, Section 8 Housing Choice Voucher 
Homeownership Program (May 11, 2015), https://files.consumerfinance.gov/f/201505_cfpb_bulletin-section-8-housing-choice-voucher-homeownership-program.pdf.
    \35\ See CFPB Bulletin 2014-03, Social Security Disability 
Income Verification (Nov. 18, 2014), https://files.consumerfinance.gov/f/201411_cfpb_bulletin_disability-income.pdf.
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    Should the Bureau provide additional clarity under ECOA and/or 
Regulation B regarding when all or part of the applicant's income 
derives from any public assistance program? If so, in what way(s)? For 
example, should it provide

[[Page 46603]]

guidance on how to address situations where creditors seek to ascertain 
the continuance of public assistance benefits in underwriting 
decisions?
    9. Artificial Intelligence and Machine Learning: As the Bureau 
noted in its annual fair lending report to Congress dated April 30, 
2020 \36\ and a blog post dated July 7, 2020,\37\ financial 
institutions are starting to deploy artificial intelligence (AI) and 
machine learning (ML) across a range of functions. For example, they 
are used as virtual assistants that can fulfill customer requests, in 
models to detect fraud or other potential illegal activity, as 
compliance monitoring tools, and in credit underwriting. Should the 
Bureau provide more regulatory clarity under ECOA and/or Regulation B 
to help facilitate innovation in a way that increases access to credit 
for consumers and communities in the context of AI/ML without unlawful 
discrimination? If so, in what way(s)?
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    \36\ See Fair Lending Report of the Bureau of Consumer Financial 
Protection (Apr. 2020), 85 FR 27395, https://files.consumerfinance.gov/f/documents/cfpb_2019-fair-lending_report.pdf.
    \37\ See Patrice Alexander Ficklin et al., Innovation spotlight: 
Providing adverse action notices when using AI/ML models (July 7, 
2020), https://www.consumerfinance.gov/about-us/blog/innovation-spotlight-providing-adverse-action-notices-when-using-ai-ml-models/.
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    Another important issue is how lenders using complex AI/ML models 
satisfy ECOA's adverse action notice requirements. ECOA requires 
creditors to provide consumers with the principal reason(s) for a 
denial of credit or other adverse action.\38\ These notice provisions 
serve important anti-discrimination, educational, and accuracy 
purposes. There may be questions about how institutions can comply with 
these requirements if the reasons driving an AI/ML decision are based 
on complex interrelationships.\39\ Should the Bureau modify 
requirements or guidance concerning notifications of action taken, 
including adverse action notices, under ECOA and/or Regulation B to 
better empower consumers to make more informed financial decisions and/
or to provide additional clarity when credit underwriting decisions are 
based in part on models that use AI/ML? If so, in what way(s)?
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    \38\ 15 U.S.C. 1691(d).
    \39\ See Fair Lending Report of the Bureau of Consumer Financial 
Protection (Apr. 2020), 85 FR 27395 (May 8, 2020), https://files.consumerfinance.gov/f/documents/cfpb_2019-fair-lending_report.pdf; Patrice Alexander Ficklin et al., Innovation 
spotlight: Providing adverse action notices when using AI/ML models 
(July 7, 2020), https://www.consumerfinance.gov/about-us/blog/innovation-spotlight-providing-adverse-action-notices-when-using-ai-ml-models/.
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    10. ECOA Adverse Action Notices: Under ECOA and Regulation B, a 
statement of reasons for adverse action must be specific and indicate 
the principal reason(s) for the adverse action.\40\ The Bureau 
understands from direct engagement and its supervisory work that 
stakeholders continue to have questions about this requirement. Should 
the Bureau provide any additional guidance under ECOA and/or Regulation 
B related to when adverse action has been taken by a creditor, 
requiring a notification that includes a statement of specific reasons 
for the adverse action? If so, in what way(s)?
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    \40\ 15 U.S.C. 1691(d)(3); 12 CFR 1002.9(b)(2).

    Authority:  12 U.S.C. 5511(c).

III. Signing Authority

    The Director of the Bureau, having reviewed and approved this 
document, is delegating the authority to electronically sign this 
document to Laura Galban, a Bureau Federal Register Liaison, for 
purposes of publication in the Federal Register.

    Dated: July 28, 2020.
Laura Galban,
Federal Register Liaison, Bureau of Consumer Financial Protection.
[FR Doc. 2020-16722 Filed 7-31-20; 8:45 am]
BILLING CODE 4810-AM-P