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Presumably, the current leadership of the CFPB would favor the reduction of the closed-end loan reporting threshold to the 25 originated loans in each of the prior two years level set by the October 2015 rule. Additionally, prior to that rule, the reporting of open-end lines of credit was optional, so there was no reporting trigger. .
Under the leadership of Acting CFPB Director Dave Uejio, the Bureau issued an interpretive rule on March 9, 2021 clarifying that the prohibition against sex discrimination under the Equal Credit Opportunity Act (“ECOA”) and Regulation B includes sexual orientation and gender identity discrimination.
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