|House SECURE Support Letter - Coalition||Reps. Madeleine Dean and Kelly Armstrong||06/11/21|
|Coalition Support Letter Regarding S3533 - HR 6364 SECURE Notarization Act||116th Congress||03/26/20|
|G-Fee Coalition Letter||Congress||03/09/20|
|Letter on FHFA Capital Rule Amendments||FHFA||11/23/21|
|Letter on FHFA Equitable Housing Finance Plans||FHFA||10/25/21|
|Letter on Enterprise Housing Goals||FHFA||10/25/21|
|Comments on Credit Score Models||FHFA||08/25/21|
|Joint Meeting Request on GSE Amendments||Treasury Department, FHFA||08/17/21|
|Housing-Finance Reform: The Community Bank Perspective||Senate Banking Committee||Written Statement||09/10/19|
|Housing Finance: The Community Bank Perspective||Senate Banking Committee||Written Statement||03/26/19|
ICBA and other groups expressed opposition to a Department of Housing and Urban Development proposal to re-implement its 2013 rule on discriminatory effects.
Proposal: HUD in June proposed rescinding its 2020 rule interpreting the Fair Housing Act’s "disparate impact" standard and restoring the 2013 rule.
2013 Rule: Under HUD's 2013 rule, lenders could be held liable for neutral practices that have a disparate impact on certain classes of borrowers, even if the lenders had no intent to discriminate.
Court Case: The 2020 rule was designed to conform with a 2015 Supreme Court ruling. In Texas Department of Housing and Community Affairs v. Inclusive Communities Project, the high court upheld the disparate-impact approach while ruling that such cases must demonstrate a robust causal link between practices and alleged discriminatory impact.
2020 Rule: In response to the Supreme Court ruling, HUD's Comment Letter on Implementation of Fair Housing Act 2020 final rule required plaintiffs to meet a five-step framework that established legal liability for facially neutral practices that have unintended discriminatory effects. The rule was blocked by a Massachusetts district court before taking effect
Joint Letter: In Tuesday’s letter, ICBA and other groups said the 2013 rule is inconsistent with the Inclusive Communities decision, which requires plaintiffs to demonstrate “robust causality” and “direct” proximate cause between the defendant’s challenged conduct and the plaintiff’s asserted injury. Therefore, the rule must be updated, they said.
More: The groups also said: