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Mar 6, 2019 at 6:23 comment added shabbychef +1, thanks again.
Mar 6, 2019 at 5:33 comment added ohwilleke @shabbychef The OCC lost jurisdiction to the CFPB under Dodd-Frank files.consumerfinance.gov/f/… (also there may be more than one agency with jurisdiction). I wouldn't be surprised at all to see a state or federal regulator sue a marketplace lender (of course, only if they break this law, something I have no reason to suspect). The Colorado attorney general recently sued several re violations of different consumer protection laws and the CA AG has also done that. See the ABA report cited above.
Mar 6, 2019 at 5:22 comment added shabbychef Thank you for this. As I understand it, the OCC is the agency that enforces ECOA. It is hard for me to imagine them taking action against individual marketplace lenders, even if their collective action results in disparate impact on borrowers.
Mar 6, 2019 at 5:19 vote accept shabbychef
Mar 6, 2019 at 1:20 history edited ohwilleke CC BY-SA 4.0
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Mar 6, 2019 at 1:14 history edited ohwilleke CC BY-SA 4.0
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Mar 6, 2019 at 1:08 history answered ohwilleke CC BY-SA 4.0