CRAM ARCADE Open App

A lender's data shows that it approves conventional mortgage applications from White applicants at a rate of 78% but approves applications from Black applicants with similar credit profiles at a rate of 52%. The lender claims its underwriting criteria are race-neutral and applied uniformly. Under fair lending law, which legal theory would a regulator MOST likely use to challenge this practice?

Ethics · 18% of the SAFE examhard

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Correct answer: Disparate impact, because a facially neutral policy produces statistically unequal outcomes

Disparate impact theory applies when a facially neutral policy or practice — uniformly applied — nonetheless produces statistically significant discriminatory outcomes against a protected class, even without proof of discriminatory intent. The lender claims race-neutral criteria, yet outcomes differ substantially between White and Black applicants with similar profiles. A regulator would analyze this through disparate impact. Disparate treatment requires proof of intentional discrimination — applying different standards to different groups — which the scenario does not establish, since the lender claims uniform criteria. Redlining involves refusing to lend in specific geographic areas based on demographics, not differential approval rates across racial groups. Reverse redlining involves targeting minority communities with predatory products, which is not described here.

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