Paper on the Use of Proxies to Determine Race/Ethnicity in Assessing Fair Lending

Yan Zhang of the Office of the Comptroller of the Currency (OCC) has written Assessing Fair Lending Risks Using Race/Ethnicity Proxies, 64 Management Science (January 2018). Here is the abstract: Fair lending analysis of non-mortgage credit products often involves proxying for race/ethnicity since such information is not required to be reported. Using mortgage data, this paper […]

Not even consumer law professors routinely read consumer contracts and disclosures.

by Jeff Sovern When I surveyed consumer law professors about the content of their courses, I also asked them whether they read consumer contracts and mandated disclosures in their personal lives.  Here is an excerpt, but the article has more: Not one professor reported always reading contracts or disclosures. In contrast, 57% said they rarely or […]

My Latest Op-Ed: Mick Mulvaney turned the CFPB from a forceful consumer watchdog into a do-nothing government cog

Here.  Excerpt: Kraininger’s supporters have noted that she acquired considerable managerial experience as an associate director at the Office of Management and Budget and deputy assistant secretary at the Department of Homeland Security. That may help her with management issues, but it’s hard to see how it will help her make decisions about which cases to bring […]

“8 States Impose New Rules on Equifax After Data Breach”

The New York Times reports that Equifax has agreed to a consent order with eight state financial regulators in response to the breach that allowed hackers to steal sensitive personal information on more than 147 million people last year. The order describes specific steps that Equifax must take, including conducting security audits at least once […]

Survey Results for the Content of Consumer Law Classes III

by Jeff Sovern I posted on SSRN the results of the survey I previously blogged about, The Content of Consumer Law Classes III.  This follows similar surveys in 2008 and 2010 (I bet you can guess what their titles are).  The abstract for the new version reads as follows: This paper reports on a 2018 survey of law […]

CFPB Drops Another Matter

by Jeff Sovern According to HousingWire, the CFPB has informed Zillow that it is dropping its investigation into Zillow for RESPA violations. We know about this because of a Zillow SEC filing. We will never know how many CFPB investigations have been dropped into companies that are not subject to SEC filing requirements. Nor can […]

Industry Publication Reports Mulvaney “Lobbying Hard” for Kraninger and Infers that Kraninger Will Carry on Mulvaney’s Legacy

by Jeff Sovern AccountsRecovery.Net has a story, Mulvaney Lobbying Hard For Kraninger, Despite Saying He Wants To Stay Out of Process, which reports: Mulvaney has spoken out publicly in favor of Kraninger’s nomination and the report [in The Hill] said that Mulvaney has reached out to several Republican members of the Senate Banking Committee, which will […]

Paper on Improvident Student Lending

Joseph Sanders and Vijay Raghavan, both of the Office of the Illinois Attorney General have written Improvident Student Lending, Utah Law Review (2018). Here is the abstract: The idea that lending without regard to ability to repay should be illegal is not particularly new, but it gained purchase in recent years with the rapid growth of high-cost […]