Comment on CFPB-2011-0019-0001

The Center for Equal Opportunity and the Pacific Legal Foundation oppose the use of an "effects" test under the ECOA for the same policy and legal reasons that we oppose it for the Fair Housing Act, a similar statute. Those reasons are discussed in the amicus brief we recently filed with the Supreme Court in Magner v. Gallagher; that brief is available from the Court and will also be posted on the Pacific Legal Foundation's website: http://www.pacificlegal.org/