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CFPB Circular – Adverse Action Based on Credit Models

On May 26, 2022, the Consumer Financial Protection Bureau (CFPB) confirmed that federal anti-discrimination law requires companies to explain to applicants the specific reasons for denying an application for credit or taking other adverse actions, even if the creditor is relying on credit models using complex algorithms. The CFPB published a Consumer Financial Protection Circular  (Circular 2022-3) to remind the public, including those responsible for enforcing federal consumer financial protection law, of creditors’ adverse action notice […]