In 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.

That data, the lender's policies, and the lender's fear of reputation risk, will then be leveraged by the CFPB to extract operational changes, and also more than likely, to extract a huge financial settlement, as well as impose a multi-million dollar civil money penalty.

And, after the CFPB finishes with its final Home Mortgage Disclosure Act rule, with its collection of 37 new data sets, all mortgage lenders in particular, will feel the crushing burden of the CFPB's disparate impact enforcement boot.

That's not something that any financial services provider should applaud.

Marvin Umholtz

President/CEO

Umholtz Strategic Planning & Consulting Services

Olympia, Wash.