DRM and Partners Reach Agreement with Baltimore City to Improve Sidewalks and Ramps for People with Mobility Disabilities

 

Disability Rights Maryland (DRM) and their legal partners Disability Rights Advocates, Fox & Robertson, and Goldstein, Borgen, Dardarian & Ho, on behalf of pedestrians with mobility disabilities, have reached a partial agreement with the City of Baltimore to make sidewalks and curb ramps more accessible for people with mobility disabilities. This is part of the class-action lawsuit Goodlaxson, et al. v. Mayor and City Council of Baltimore (Case No. 1:21-cv-01454-JKB).    In 2021, DRM and their legal partners filed the lawsuit on behalf of several individuals and organizations, including Susan Goodlaxson, Janice Jackson, Keyonna Mayo, and the IMAGE Center of Maryland. They argued that Baltimore City failed to follow federal disability laws because many of its sidewalks and curb ramps were not built or maintained to be accessible, making it harder for people with disabilities to safely travel around the city and take part in community life.    Baltimore City’s own data shows the issue is widespread. A 2019 review found that only about 1.3% of surveyed curb ramps met ADA (Americans with Disabilities Act) standards. Many sidewalks were also damaged or too narrow for wheelchairs and other mobility devices, forcing people with disabilities to use the street alongside traffic, which is dangerous.    This lawsuit aimed to help everyone with mobility disabilities who has had difficulty using Baltimore’s sidewalks, curb ramps, and pedestrian pathways because they were too steep, narrow, or damaged. The agreement, a partial consent decree, is a step toward fixing these problems. Beginning in the third year of the agreement, the parties will work on a long-term plan to make all sidewalks and ramps accessible.

What Baltimore City Agreed to Do:   Spend $44–50 Million Over Four Years  The City will repair or build thousands of curb ramps and fix tens of thousands of square feet of sidewalks. Focus on Key Areas First Improvements will start in important places like government offices, transportation hubs, hospitals, and business areas -  especially in high-need neighborhoods. Improve the 3-1-1 System People with mobility disabilities can use the City’s 3-1-1 system to report broken sidewalks or ramps. Baltimore City will: Investigate issues within 60 days.  Provide a timeline for fixing the issue within 10 days after the investigation. Aim to fix the problem within nine months.  Quickly respond to complaints about puddles forming on ramps.  Hire ADA Coordinators  Baltimore will appoint coordinators to ensure the repairs meet ADA standards. Raise Awareness The City will educate the public about keeping sidewalks and ramps clear of snow and debris, especially near bus stops and public transportation. Create a Public Database  Baltimore City will maintain an online system to track the conditions of sidewalks and curb ramps.

Source: Disability Rights Maryland email, December 19, 2024

CFPB Sues Comerica Bank for Systematically Failing Disabled and Older Americans

The Consumer Financial Protection Bureau (CFPB) has sued Comerica Bank for systematically failing its 3.4 million Direct Express cardholders - disabled and older Americans who receive Social Security and other federal benefits. The bank deliberately disconnected 24 million customer service calls, impeding cardholders from exercising their rights under the law, charged illegal ATM fees to over 1 million cardholders, and mishandled fraud complaints while providing federal benefits through the Direct Express prepaid debit card program. The CFPB is asking the court to order Comerica to stop these practices, provide refunds to affected customers, and pay civil penalties to the CFPB's victim relief fund.

Comerica Bank is a subsidiary of Comerica Inc. (NYSE: CMA), among the 25 largest bank holding companies in the U.S. Incorporated in Delaware, it is headquartered in Texas. Comerica reported total assets of more than $84 billion and total deposits of over $71 billion. Since 2008, the U.S. Department of Treasury has contracted with Comerica Bank to administer the Direct Express program, in which 3.4 million federal beneficiaries receive their monthly benefits payments through prepaid debit cards. Direct Express is a prepaid card that beneficiaries can use to pay for groceries, gas, and other expenses.  

Comerica is in charge of customer service for the millions of Americans using Direct Express, many of whom are unbanked. Rather than ensuring that there was sufficient customer service to handle calls from the benefits recipients, Comerica instead boosted its bottom line. When people had problems with their accounts, it was often impossible to talk to someone for help. 

The CFPB’s investigation found that Comerica failed to ensure sufficient staff and even intentionally disconnected more than 24 million calls. The CFPB alleges that Comerica harmed its customers by:

• Deliberately disconnecting customer service calls: Comerica’s vendors intentionally dropped over 24 million calls from customers before they could reach a representative. Customers whose calls were not dropped were routinely forced to endure excessively long wait times - often more than several hours - to speak with a representative to get help with unauthorized transactions, charge disputes, and lost or stolen cards.
• Charging consumers illegal ATM fees: Over one million Direct Express cardholders were charged ATM fees to access their government benefits in situations where they were legally entitled to free withdrawals.
• Misleading fraud victims: When consumers contacted Comerica alleging they had been fraudulently enrolled into the Direct Express program, the bank’s vendors frequently advised the consumers that “no error occurred” although the bank had determined that there was, in fact, enrollment fraud.
• Imposing illegal terms of service on consumers seeking to stop payments: Comerica led its consumers to agree to waive their consumer protections by requiring cardholders to contact and request merchants to stop pre-authorized payment transfers from their account in situations where the law in fact required the bank to stop the transfers itself.
• Failing to investigate account problems: Under federal law, when a customer notifies a bank about an incorrect or potentially fraudulent charge on their account, the bank must take steps to investigate the error within a specified time period. The CFPB’s investigation found that Comerica failed to meet this requirement more than 20,000 times. When they did investigate, they frequently provided vague and confusing findings or blew off customers altogether.
• Forcing consumers to close accounts, which often resulted in additional fees: The bank’s vendors required thousands of cardholders to close their accounts to stop a preauthorized payment, resulting in consumers incurring additional fees to expedite receipt of their new debit cards to regain access to their government benefits.

Under the Consumer Financial Protection Act, the CFPB has the authority to take action against institutions violating consumer financial protection laws, including engaging in unfair, deceptive, or abusive acts and practices. The CFPB’s lawsuit seeks to stop Comerica’s unlawful conduct, to provide redress for harmed borrowers, and the imposition of a civil money penalty, which would be paid into the CFPB’s victims relief fund. Read today’s complaint.

Consumers can submit complaints about financial products and services by visiting the CFPB’s website or by calling (855) 411-CFPB (2372).

Employees who believe their company has violated federal consumer financial protection laws are encouraged to send information about what they know to whistleblower@cfpb.gov. To learn more about reporting potential industry misconduct, visit the CFPB’s website.

The Consumer Financial Protection Bureau is a 21st century agency that implements and enforces Federal consumer financial law and ensures that markets for consumer financial products are fair, transparent, and competitive. For more information, visit www.consumerfinance.gov.

Read the December 6, 2024 CFPB article.

The Just Economy Conference 2025 will be on March 26-27, 2025

Washington Hilton

1919 Connecticut Avenue

Washington, D.C. 20009

Register

Hill Day • March 25

The Just Economy Conference is the national event for community, business, foundation, policy and government leaders who want a nation that not only promises but delivers opportunities for all Americans to build wealth and live well. National and local luminaries, visionaries and changemakers gather to network, share ideas, learn and ask hard questions to chart out a better future.

Along with keynote speakers and conversations on the main stage, the conference includes a wide range of conversational sessions and workshops.

 Topics include:

• Community organizing and advocacy
• Fair housing
• Fair lending
• Access to capital and credit
• Workforce and community development
• Business
• Education
• Climate change
• Healthcare
• Impact investing
• Civil and human rights, and others.

Super Earlybird Pricing

General Admission - $700

Nonprofit - $450

NCRC Organization Member - $250

Just Economy Club Member - $350

Student/Intern - $85

Retired - $85

Stay Informed:

Subscribe to our newsletter to stay updated on the Just Economy Conference.

National Community Reinvestment Coalition

740 15th St NW, Suite 400

Washington, DC 20005

11 Salisbury University Fraternity Members & Associates Charged with Assault & Hate Crime

Salisbury, Maryland police have arrested 11 men linked to a fraternity in connection with an assault in October, 2024 that led to hate crime charges. Police said detectives spoke with witnesses and obtained multiple cellphone videos of a man assaulted by several college-aged men on October 15. Detectives were able to identify and meet with the victim, who said a group of men used dating and social messaging apps to invite him to an apartment on University Terrace allegedly under false pretenses of having sex.

According to court charging documents obtained by WBALTV Channel 11 News, the suspect who reached out to the victim represented himself as a 16-year-old person. Police said the victim went to the apartment, where he was surrounded, kicked, punched, and spat upon while the assailants called him derogatory, homophobic names. The charging documents state that one of them struck the victim with a baking sheet. Police said the victim tried to leave several times but was thrown to the floor every time.

As a result, the victim suffered bruising throughout his body and a broken rib and went to a hospital in Cambridge. The charging documents state that the victim did not notify law enforcement of the attack because he was in fear of his safety and retaliation. Investigators said they believe the victim was targeted as a result of his sexual orientation.

Police released the identities of seven of the men charged with first-degree assault, false imprisonment, reckless endangerment, and hate crime offenses: Ryder Baker, 20, of Olney; Bennan Aird, 18, of Milton, Delaware; Riley Brister, 20, of Davidsonville; Cruz Cespedes, 19, of Jarrettsville; Dylan Earp, 20, of Gambrills; Elijah Johnson, 19, of Crofton; and Zachary Leinemann, 18, of Crofton.

The charging documents state that Brister confessed to his involvement in the assault, including kicking, slapping, pushing the victim, and preventing him from leaving the apartment. The charging documents state that one of the suspects, during an interview with detectives, identified others involved in the incident. Police said the suspects are members and/or associates of a fraternity at Salisbury University.

Anyone with information is asked to call Salisbury police at 410-548-3165 or Crime Solvers at 410-548-1776.

Read the November 7, 2024 WBALTV news article.

Read the November 8, 2024 CNN article.

Yehuda Bauer, Preeminent Historian of the Holocaust and Antisemitism, 98

 

Bauer, who fled Nazi Europe shortly before World War II and became one of the foremost historians of the Holocaust, combined academic rigor with humanity as he confronted an unfathomable event and sought to discern its meaning for the future. As a young Israeli historian, he did not set out to become an authority on the Holocaust, or the Shoah, another term used to describe the murder of 6 million Jews by the Nazis and their collaborators. Over the next half-century, Dr. Bauer wrote dozens of books that helped form the foundation of modern understanding of the Holocaust and antisemitism. He had lost his extended family in the slaughter, and his work served, in part, to document what had befallen them and so many other victims of Nazi persecution. But he did not regard it as his role simply to “memorialize” the dead, he wrote in his book Rethinking the Holocaust (2001). Instead, he wrote, “I ask questions about what happened and why.” That line of inquiry led him to move beyond existing Holocaust scholarship, which relied in large part on the Nazi bureaucracy’s paper trail and centered on the perpetrators. No true understanding of the Holocaust would ever be reached, Bauer maintained, without studying the victims.

In books including They Chose Life: Jewish Resistance in the Holocaust (1973), Bauer challenged a pernicious notion circulating at the time that Jews went “like sheep to the slaughter.” Citing diaries, correspondence, and oral histories, he showed that the Warsaw ghetto uprising of 1943 - when hundreds of Jewish fighters mounted the best known revolt against the Nazis - was far from the only act of insurrection by Jews in ghettos or elsewhere. He also highlighted on the everyday efforts by Jews to retain the dignity that the Nazis tried to strip away.

Bauer wrote extensively about the American response to the Holocaust, including in the book American Jewry and the Holocaust: The American Jewish Joint Distribution Committee, 1939-1945 (1981), and was among scholars who argued that President Franklin D. Roosevelt was unfairly condemned for what critics regarded as his insufficient efforts to stop the Holocaust as it was in progress. Later, Bauer had the painful experience of observing the emergence of pseudo-historians who sought to deny that the Holocaust had occurred or to suggest that the killing had been more limited than was generally understood.

Bauer taught for years at Hebrew University; served as an academic adviser to Yad Vashem, the Holocaust remembrance center in Jerusalem; and helped found the journal Holocaust and Genocide Studies. He explored topics including the founding of the state of Israel and the nature of modern antisemitism. His final books included The Jews: A Contrary People (2014). Bauer’s honors included the Israel Prize, one of the country’s highest honors, bestowed on him in 1998. He spoke critically of Israeli leaders, particularly Prime Minister Benjamin Netanyahu, whom he accused of using the Holocaust for nationalistic purposes and as a “tool for politics.”

Read the October 22, 2024 Washington Post article.

Read the entry on Bauer in the Jewish Virtual Library.

Lily Ebert, Who Kept Holocaust Memory Alive on TikTok, 100

Ebert, a Hungarian-born Auschwitz survivor who devoted herself to keeping the memory of the Holocaust alive, including on TikTok, where she drew millions of viewers with her testimonials. She also wrote a best-selling memoir, Lily’s Promise.

The title of Ebert’s book referenced a pledge that she made to herself on Yom Kippur, the holiest day in the Jewish calendar, as a 20-year-old prisoner at Auschwitz, the Nazi death camp in occupied Poland, in 1944. Her mother and her two youngest siblings had been sent directly to the gas chamber. Beneath the heavy smoke from the crematorium, Ebert vowed that she would “tell the world what had happened” not only to her “but to all the people who could not tell their stories.”

Ebert spoke to students, to historians, to politicians, and to journalists. In February 2021, her TikTok account started and it made her an unexpected social media celebrity. In one video, she showed the tattoo branded on her arm upon her arrival at Auschwitz, number A-10572. The TikTok account attracted 2 million followers. In 2023, Ebert was made a Member of the Order of the British Empire by King Charles III in recognition of her efforts to educate the public about the Holocaust. 

In Auschwitz, she wrote, “a pall hung over everything, blocking out the sun. The foul smell that had choked us on our arrival, the most sickening and overwhelming smell I had ever experienced, was getting stronger and stronger. Not far away was a tall chimney, smoking furiously, with flames emerging red and bright.” “What kind of factory is that?” she asked another prisoner. “What are they making here? What’s this horrible smell?” “They’re burning your families there,” the woman replied. “Your parents, your sisters, your brothers. They’re burning them.”

After Ebert’s death, King Charles offered his condolences, as did British Prime Minister Keir Starmer. In a statement recalling Ebert’s vow to speak of what she had witnessed, Starmer said that she had kept her promise “in the most remarkable way,” and that now “we must keep our promise to her” by carrying forward the memory of the Holocaust.

Image Credit: Holocaust Memorial Day Trust.

Read the October 11, 2024 Washington Post article.

Thelma Jean Mothershed Wair, One of the Little Rock Nine, 83.

Thelma Jean Mothershed Wair was a member of the Little Rock Nine, the African-American students involved in the desegregation of Little Rock Central High School in 1957. The world watched as they braved constant intimidation and threats from those who opposed desegregation of the formerly all-white high school. Mothershed was a junior when she entered Central. Despite the fact that she had a cardiac condition since birth, she had a near perfect record for attendance.

Mothershed attended Dunbar Junior High School and Horace Mann High School before transferring to Central High. Despite daily tormenting from some white students at Central High, she completed her junior year at the formerly all-white high school during the 1957-58 year. The students who integrated Central High School were known as the Little Rock Nine.

For three weeks in September 1957, Arkansas Governor Orval Faubus used the National Guard to block the Black students from enrolling in Central High. This was three years after the U.S. Supreme Court declared segregated classrooms were unconstitutional. In response to Faubus' actions, President Dwight D. Eisenhower sent members of the Army’s 101st Airborne Division to escort the students into school on September 25, 1957.

Because the city’s high schools were closed the following year, Mothershed earned the necessary credits for graduation through correspondence courses and by attending summer school in St. Louis, Missouri. She received her diploma from Central High by mail. Mothershed graduated from Southern Illinois University at Cabondale in 1964 with a BA in home economics and earned her MS in Guidance and Counseling Education in 1970; in 1985, she received an administrative certificate in education from Southern Illinois University at Edwardsville. She taught home economics in the East St. Louis school system for twenty-eight years.

Mothershed Wair also worked at the Juvenile Detention Center of the St. Clair County Jail in St. Clair County, Illinois, and as an instructor of survival skills for women at the American Red Cross Shelter for the homeless. During the 1989-90 school year, the East St. Louis chapter of the Top Ladies of Distinction and the early childhood/pre-kindergarten staff of District 189 honored her as an Outstanding Role Model.

The National Association for the Advancement of Colored People (NAACP) awarded her and the other Little Rock Nine, along with Daisy Bates, the prestigious Spingarn Medal in 1958. In 1999, President Bill Clinton presented the nation’s highest civilian award, the Congressional Gold Medal, to the members of the Little Rock Nine.

Image Credit: Office of U.S. Rep Vic Snyder (D-Arkansas), Public domain, via Wikimedia Commons.

Read the October 28, 2024 Encyclopedia of Arkansas article.

Read the October 21, 2024 Associated Press (AP) article.

Justice Department Secures Over $6.5M from Citadel Federal Credit Union for Redlining Philadelphia Area Black and Hispanic Communities

 

The U. S. Department of Justice (DOJ) just announced that Citadel Federal Credit Union has agreed to pay over $6.5 million to resolve allegations that it engaged in a pattern or practice of lending discrimination by redlining predominantly Black and Hispanic neighborhoods in and around Philadelphia in violation of the Fair Housing Act (FHA) and the Equal Credit Opportunity Act (ECOA). This is DOJ’s first redlining settlement with a credit union under its Combating Redlining Initiative.

The DOJ complaint, filed in the Eastern District of Pennsylvania, alleges that, from at least 2017-2021, Citadel failed to provide mortgage lending services to majority-Black and Hispanic neighborhoods in and around Philadelphia and discouraged people wanting credit there from obtaining home loans. Citadel’s home mortgage lending was disproportionately in white areas around Greater Philadelphia. Similar lenders generated mortgage applications in predominately Black and Hispanic neighborhoods at almost three times that of Citadel and originated mortgage loans in these areas over three times Citadel's rate.

The complaint also alleges that Citadel’s branches are situated almost solely in majority-White neighborhoods, with no branches in Philadelphia, which has over 75% of the majority-Black and Hispanic neighborhoods and 34% of the total population in Citadel’s market area.

Under the proposed consent order, subject to court approval, Citadel has agreed to invest $6.52 million to increase credit opportunities for communities of color in and around Philadelphia. Citadel will:

• Invest at least $6 million in a loan subsidy fund to increase access to home mortgage, home improvement, and home refinance loans for residents of majority-Black and Hispanic neighborhoods in Philadelphia.
• Spend at least $250,000 on community partnerships to provide services related to credit, consumer financial education, homeownership, and foreclosure prevention for residents of predominantly Black and Hispanic neighborhoods in its market area.
• Spend at least $270,000 for advertising, outreach, consumer financial education, and credit counseling in predominantly Black and Hispanic neighborhoods in Philadelphia.
• Open three new branches in predominantly Black and Hispanic neighborhoods in Philadelphia.
• Hire a community lending officer to oversee the continued development of lending in communities of color.
• Hire independent consultants to strengthen its fair lending program and better meet the communities’ mortgage credit needs.
• Conduct a community credit needs assessment, evaluate its fair lending compliance management systems, and conduct staff trainings.

With assets of approximately $6 billion, Citadel is headquartered in Pennsylvania and has 24 branches in Greater Philadelphia, including Bucks, Chester, Delaware, Lancaster, Montgomery, and Philadelphia Counties. The second largest credit union in the area with over 263,000 members, Citadel cooperated with the DOJ investigation.

Since 2021, the DOJ's Combating Redlining Initiative, a coordinated enforcement effort to address this persistent form of discrimination against communities of color, has announced 14 redlining resolutions and secured over $144 million in relief for communities of color that have been the victims of lending discrimination. 

A copy of the complaint and information about DOJ’s fair lending enforcement work is at www.justice.gov/fairhousing. Individuals may report lending discrimination by calling the Justice Department’s housing discrimination tip line at 1-833-591-0291 or submitting a report online.

Read the October 10, 2024 DOJ press release.

FBI 2023 Crime in the Nation Statistics Find Hate Crime Incidents Reached a Record High of 11,862 - 15% were Anti-Jewish

 

The FBI just released detailed data on over 14 million criminal offenses for 2023 reported to the Uniform Crime Reporting (UCR) Program by participating law enforcement agencies. Over 16,000 state, county, city, university and college, and tribal agencies, covering a combined population of 94.3% inhabitants, submitted data to the UCR Program through the National Incident-Based Reporting System (NIBRS) and the Summary Reporting System.

The data reveals that reported hate crime incidents were a new high of 11,862 in 2023. Although Jews only make up around 2% of the U.S. population, reported single-bias anti-Jewish hate crimes were 15% of all hate crimes reported and 68% of all reported religion-based hate crimes. Hate crimes were defined as offenses being motivated by bias toward race, ethnicity, ancestry, religion, sexual orientation, disability, gender, and gender identity.  

The FBI’s crime statistics estimates, based on reported data for 2023, show that national violent crime decreased an estimated 3.0% in 2023 compared to 2022:  

• Murder and non-negligent manslaughter recorded a 2023 estimated nationwide decrease of 11.6% compared to 2022.  
• In 2023, the estimated number of offenses in the revised rape category saw an estimated 9.4% decrease.  
• Aggravated assault decreased an estimated 2.8% in 2023. 
• Robbery decreased 0.3% nationally.  

To publish a national trend, the FBI’s UCR Program used a dataset of reported hate crime incidents and zero reports submitted by agencies reporting six or more common months or two or more common quarters (six months) of hate crime data to the FBI UCR Program for 2022 and 2023. According to this dataset, reported hate crime incidents decreased 0.6% from 10,687 in 2022 to 10,627 in 2023.  

The complete analysis is located on the FBI’s Crime Data Explorer.

Read the September 23, 2024 FBI article.

Baltimore City Civil Rights Week 2024 Programming Announcement

The Office of Equity and Civil Rights is excited to invite you to join us for our annual Civil Rights Week from October 4th - 12th! We have several events scheduled throughout the week that touch on key topics including Police Accountability, The History of Redlining and Housing Discrimination in the city, Legislative Access for Women, a History of Immigration and Inclusion in Baltimore and more! Check out some of what's happening below and sign up to join us. All events are free and open to the public. Hope to see you there! Register Here!

US Antisemitic Incidents Surge to Record High

Reports of antisemitic incidents in the US have reached a record high since last year's Hamas attack in Israel, according to a preliminary report from the Anti-Defamation League Center for Extremism (ADL). The group found over10,000 incidents from 7 October 2023 to 24 September of this year, more than a 200% increase compared to the same period last year. It is the highest ever since the ADL began tracking such incidents in 1979.

The report is days after the FBI and Department of Homeland Security issued a joint statement warning of possible violent threats amid the ongoing turmoil in the Middle East. Since last October’s Hamas attack on Israel which saw around 1,200 people killed "Jewish Americans haven’t had a single moment of respite,” ADL CEO Jonathan Greenblatt said in a statement. “Instead, we’ve faced a shocking number of antisemitic threats and experienced calls for more violence against Israelis and Jews everywhere.”

The antisemitism episodes reported by the ADL included about 8,015 incidents of verbal or written harassment, 1,840 incidents of vandalism, and 150 incidents of physical assault. The states with the highest number of recorded cases were California, with 1,266 incidents, New York 1,218, New Jersey  830, and Florida 463. The ADL expects its preliminary numbers to increase as it receives more data. The final report for 2024 will be published in the spring of 2025.

Part of the overall increase comes from a change in methodology to include "expressions of opposition to Zionism, as well as support for resistance against Israel or Zionists that could be perceived as supporting terrorism", the ADL said. The ADL's preliminary report counted over 3,000 of incidents during anti-Israel rallies "which featured regular explicit expressions of support for terrorist groups", including Hamas and Hezbollah. Excluding these incidents, the ADL counted 7,523 episodes of antisemitism, a 103% increase from 2022.

The continued violence in the Middle East region has led to a surge in anti-Muslim and Islamophobic incidents across the US. Anti-Muslim incidents were 8,061 in 2023, according to a report from the Council on American-Islamic Relations (CAIR) released this April. This was the highest level since CAIR began tallying almost 30 years ago, with nearly half coming after the 7 October attack.

Read the October 6, 2024 BBC News article.

NCRC and Fintechs Urge Federal Regulators to Use AI to Detect and Eliminate Lending Discrimination

 

The National Community Reinvestment Coalition (NCRC) and a group of financial technology firms submitted a joint letter urging regulators issue clear guidelines to lenders on how the new AI fair lending tools could better evaluate disparities in lending. The letter to the Consumer Financial Protection Bureau (CFPB) and Federal Housing Finance Agency (FHFA) - signed by NCRC, Zest AI, Upstart, Stratyfy, and FairPlay - was issued in response to the White House’s Executive Order on AI in October, 2023.

Some lenders have not adopted these newer tools for underwriting analysis because they believe they can remain compliant with existing fair lending laws despite evidence that suggests older scoring models continue to contribute to systemic discrimination. Newer fair lending tools can allow lenders to conduct searches for new underwriting models that perform as well as older scoring models, while also mitigating the risk of discrimination in their analysis of an LMI credit applicant.

From the companies’ perspective, the power of the new AI tools can help lenders comply with regulations and improve their ability to expand credit access to applicants who have traditionally been underserved or considered too risky by old underwriting models.

The key recommendations of the letter include:

1. Don’t wait for perfect information to act. AI will continue to rapidly evolve. Supervisory highlights should be used by regulators to highlight best practices within the industry.
2. Provide written guidance on activity that triggers fair lending oversight. The CFPB should provide clearer guidelines on the conditions that would require a lender to engage in a Less Discriminatory Alternative (LDA) search, as well as the frequency with which such searches will be conducted.
3. Clarify that fair lending applies not only to how applicants are treated, but also how they are selected. Evaluating the creditworthiness of applicants can happen at the earliest stages of the lending process, including during marketing campaign planning. AI tools that can more comprehensively assess the risk of an applicant should be adopted earlier and favored over older models and tools.
4. The FHFA should continue to build upon its 2022 AI Advisory Opinions. The prior advisory opinions offered AI-specific guidance to the GSEs based on select use cases with potential to improve housing finance for consumers.
5. The CFPB should assert that fair lending compliance should be as high a priority as all other parts of the lending process. For companies using AI in credit decisioning, the CFPB should make clear the usage of outdated tools is not sufficient to remain compliant with fair lending laws.
6. Supervisory examination and training should address routine review of financial institutions’ model testing protocols and results. Fair lending examinations should also include reviews of the models used, testing protocols and positive assessment of LDA searches. Data concerning the efficacy of tools and practices should be shared in a forum with regulators and policymakers.

Photo by BoliviaInteligente on Unsplash

Read the September 30, 2024 NCRC article.

Stakeholder Meeting of 2025 Baltimore Regional Fair Housing Analysis is October 1

The third large stakeholder meeting of the Baltimore Metropolitan Council's 2025 Baltimore Regional Fair Housing Analysis will be gathering in person over lunch on Tuesday, October 1 at the Harriet Tubman Cultural Center in Columbia. Lunch is 11:30 a.m. and the meeting is noon. Please register on the project page and indicate your lunch preference if you can join in person. If you need to join remotely, you can register on Zoom. 

"At this meeting we will hear again from our working groups on Enforcement in the Private Market, Housing Supply and Siting of Affordable Housing, and Fair Housing Barriers for Renters. We will also review the most relevant new data from our consultants at Root Policy Research, and we are likely to start discussing potential action steps. 

The site for our meeting was formerly Harriet Tubman High School, a segregated school for Black Howard County residents built in the late 1940s near a local Black community. The school closed when Howard County had fully integrated its schools -- one grade at a time -- in 1965, eleven years after the Brown v. Board of Education Supreme Court decision. Harriet Tubman High School was never integrated. Now the school building is a County historical, cultural, and educational center, hosting camps and visits and featuring hybrid meeting capability for gatherings like this one. It also has historical displays and rooms that document key aspects of Howard County's history. We encourage you to come early or stay afterwards and take a look around. If there is enough interest, we may try to organize an informal tour before or after the meeting. 

Please let us know if you can join us, either in person or remotely on October 1. And feel free to reach out to me at dpontious@baltometro.org with any questions. I am out this week, but can get back to you next week. We hope to see you October 1!"

Contact:

Dan Pontious, Housing Policy Coordinator, P: 410-732-0500 x1055, dpontious@baltometro.org
Baltimore Metropolitan Council 
1500 Whetstone Way, Suite 300
Baltimore, Maryland 21230

¡Almuerzo para celebrar el 60.º aniversario de la aprobación de la Ley de Derechos Civiles!

 

Únase a la Comisión de Derechos Civiles de Maryland, la Oficina de Equidad y Derechos Humanos del Condado de Anne Arundel, el Consejo Asesor Comunitario de la Oficina de Diversidad, Equidad e Inclusión del Condado de Baltimore, la Oficina de Derechos Humanos y Equidad del Condado de Howard, la Oficina de la Oficina del Condado de Montgomery de Derechos Humanos y la Oficina de Derechos Humanos del Condado de Prince George para nuestra celebración del 60º aniversario de la Ley de Derechos Civiles de 1964. Esta legislación transformadora ha sido un pilar de nuestra democracia, ayudando a acercar a nuestra nación a nuestra promesa fundacional de libertad y justicia para todos. Nuestra Celebración conmemorará el coraje y el sacrificio de innumerables héroes de los derechos civiles que dieron origen a esta histórica legislación. LOS BOLETOS CUESTAN $60. HAGA CLIC EN EL VOLANTE PARA COMPRAR ENTRADAS

Victim of Discrimination? Training & Partnerships

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