Our Statement on Preserving Fair Lending Rules
Beneficial State Foundation
December 15, 2025
Erin Kilmer Neel, Executive Director of Beneficial State Foundation, released the following statement regarding proposed amendments to Regulation B of the Equal Credit Opportunity Act and Section 1071 small business lending data collection rules
Fair lending laws only work when regulators have the tools to enforce them. The Consumer Financial Protection Bureau’s proposed rollbacks to Regulation B and Section 1071 would eliminate or restrict key frameworks that enable enforcement, threatening decades of progress toward equitable credit access.
From disparate impact analysis to robust data collection, these frameworks enhance regulators’ ability to identify discriminatory patterns and take action to ensure all communities have fair access to credit. Without them, systemic barriers are likely to persist in credit markets, leaving qualified borrowers unable to access the capital they need to buy homes, start businesses, and build financial security.
Through our work with lenders nationwide, we have seen how clear regulatory frameworks enable institutions to innovate and expand access while maintaining sound underwriting practices. Weakening these frameworks creates a fragmented market where some institutions proactively address barriers while others face no obligation to do so. With the proposed changes, borrowers’ access to credit would largely depend on which lender they approach rather than their actual capacity to repay.
Strong, consistent fair lending standards benefit everyone — borrowers, responsible lenders, and the broader economy. We urge regulators to preserve proven fair lending tools that help ensure qualified applicants can access the capital they need to thrive. In the meantime, our partners at the National Community Reinvestment Coalition have created a tipline where consumers can continue to lodge complaints about discriminatory practices.
Comment Letters:
###
About Beneficial State Foundation
Beneficial State Foundation is a 501(c)3 nonprofit that equips and connects bank leaders to create financial wellbeing for all. For over a decade, the Foundation’s research, programming, and partnerships have improved racial, economic, and environmental outcomes across the banking industry. For more information, visit www.beneficialstate.org.
