Removing Barriers Blog

Comments sent to HUD re: Disparate Impact
Posted October 21, 2019 by CUNA Advocacy

Last week, CUNA filed a comment letter in reference to HUD’s notice of proposed rulemaking on the “Implementation of the Fair Housing Act’s Disparate Impact Standard. In the comment letter, CUNA notes that credit unions firmly believe that illegal discrimination should have no place in the financial services market and that individuals and institutions engaging in discriminatory behavior should and must be penalized.  

As part of those efforts, however, it is essential that both financial institutions and consumers have a clear understanding of the standards imposed by the law and the requirements for demonstrating compliance with its mandates. To that end, CUNA supports HUD’s proposed revisions to its existing rules on the burden of proof for disparate-impact claims under the Fair Housing Act in order to conform to the standards outlined by the Supreme Court in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc.