WASHINGTON,, DC (December 15, 2025) |
Today, the Defense Credit Union Council, DCUC, provided formal comments to the Consumer Financial Protection Bureau (CFPB) regarding the agency’s proposed amendments to the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B.
In the letter, DCUC expressed general support for the CFPB’s efforts to clarify regulatory requirements and reduce compliance uncertainty.
The letter highlights key areas of support, including:
Disparate Impact Claims: DCUC agrees with the CFPB’s proposal to align Regulation B with the ECOA’s statutory language, which does not authorize disparate impact claims. This change is expected to provide greater regulatory clarity and more consistent enforcement, while continuing to protect consumers from discrimination.
Discouragement Provisions: DCUC supports revisions clarifying what constitutes prohibited discouragement of credit applicants. DCUC urges the CFPB to retain language that encourages lenders to actively reach out to underserved groups, an important practice for credit unions serving military communities.
Special Purpose Credit Programs: DCUC welcomes regulatory updates aimed at preventing discriminatory use of special purpose credit programs by for-profit organizations, but stresses that credit unions must maintain flexibility to partner with community organizations to expand access to credit.
“Credit unions are deeply committed to fair and inclusive lending, particularly in support of our military members and their families,” reminds Jason Stverak, DCUC Chief Advocacy Officer. “We appreciate the CFPB’s efforts to streamline regulatory requirements and provide clear guidance that allows credit unions to innovate and serve their members effectively.”
DCUC looks forward to continued collaboration with the CFPB as these proposals move forward.