CFSL Bulletin The latest Consumer Financial Services Litigation news, developments, and legal thinking

Category Archives: Lending Discrimination

New Risks for Indirect Lenders

Posted in Equal Credit Opportunity Act; Lending Discrimination

Last month the Consumer Financial Protection Bureau announced that it will start holding banks accountable for the discriminatory actions of indirect auto lenders. The issue arises when a consumer goes to purchase a car and applies for financing right at the dealership. That dealer then takes the loan application and submits it to a bank which either declines the loan or offers to make the loan at a fixed rate. Pursuant to the dealer’s arrangement with the bank, it can then markup the loan in what is known in the industry as “dealer reserve.” Its not that different from a yield spread premium in the mortgage industry.  

For years there has been litigation about whether banks can be held accountable for a dealer’s discriminatory markups. Some courts say yes. Some say no. The CFPB has now weighed in and as a result we can expect many more of these types of cases. The CFPB has found that giving discretion to dealers to markup loans creates a significant risk of price disparity based on race, national origin and potentially other prohibited bases.

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7th Circuit Finds ECOA Provides Relief Against Loan Modification Proposals

Posted in Fair Housing Act; Lending Discrimination

In Estate of Davis v. Wells Fargo Bank, 2011 WL 93030 (7th Cir. Jan. 12, 2011), the plaintiff asserted claims arising from her 1999 mortgage loan refinancing which, in a prior action against the original defunct lender, was determined to have been fraudulent. In 2002, the plaintiff defaulted on her loan and Wells Fargo Bank, as the ultimate assignee of the loan, made various attempts, in conjunction with the loan servicer, Litton Loan Servicing, to obtain repayment of the loan from the plaintiff. In one such attempt, in 2005, the loan servicer sent the plaintiff a loan modification proposal on behalf of Wells Fargo.

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Third Circuit Furthers Split Regarding Use of McDonnell Douglas Test in Lender Discrimination Suits

Posted in Lending Discrimination

In Anderson v. Wachovia Mortgage Corporation, the Court of Appeals for the Third Circuit furthered a split between the Circuits by holding that the direct evidence test introduced by Price Waterhouse v. Hopkins, and the burden-shifting framework established by McDonnell Douglas Corp. v. Green, may be used to investigate claims of discriminatory lending under § 1981. The Circuit split furthered by the Third Circuit’s decision in Anderson will require claimants to use different standards when making a prima facie case of lending discrimination under § 1981 depending upon the Circuit in which their claims are brought.

The appellants in Anderson were three African-American couples who purchased adjacent homes in a Dover, Delaware community. The couples brought a case against their lender, Wachovia Mortgage Corporation, after the lender imposed several conditions on the approvals of their respective mortgages; conditions that the appellants claim were imposed solely because they were African-Americans attempting to purchase property in a predominately Caucasian neighborhood.

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