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marvin umholtzIn the wake of the Supreme Court’s 5 to 4 “blessing” of the dubious disparate impact theory’s statistical methodology that doesn’t even prove actual discrimination, all lenders should spend huge sums of money implementing complex and costly fair lending compliance program upgrades.

If the lender doesn’t, the CFPB and the other federal regulators, will be investigating the lender’s data, and the data held by the lender’s vendors, and scrubbing it in search of hypothetical discrimination.

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