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CFPB, DOJ Withdraw 2023 Guidance on Lenders’ Use of Immigration Status

Officials say the move reaffirms lenders may factor lawful residence where relevant to creditworthiness.

Overview

  • The agencies formally rescinded an October 2023 joint statement, saying it created a misimpression that ECOA or Regulation B limits consideration of immigration or citizenship status.
  • They emphasized that creditors may weigh immigration status to assess repayment risk, protect creditor rights and remedies, and comply with other laws.
  • The withdrawal aims to avoid legal confusion, reduce unnecessary compliance burdens, and prevent any misreading of potential liability under 42 U.S.C. § 1981.
  • Acting CFPB Director Russell Vought and DOJ Civil Rights Division head Harmeet K. Dhillon said the step restores alignment with established federal civil rights law.
  • Legal experts warned the change could restrict access to credit for some noncitizens and reflects the administration’s broader rollback of Biden-era regulatory guidance.