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Victimless Violations

Can a fair lending enforcement action occur when no specific victims are identified?

Absolutely yes. Most redlining cases are based on aggregate date. No specific victims are identified. In one recent case the lenders were cited for violations primarily based on statements made during a periodic podcast.


Learn more about Jack Holzknecht and Robin Cooper’s webinar

Lessons Learned: Recent Lending Compliance Enforcement Actions

First published on 09/06/2020

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