Fair Housing

A Minnesota lender's underwriting software automatically declines loans for properties in certain zip codes due to historical performance data. If those zip codes correspond to minority-concentrated areas, this practice may violate:

AOnly the Fair Housing Act
BThe Fair Housing Act and the Equal Credit Opportunity Act (ECOA)✓ Correct
COnly the Community Reinvestment Act (CRA)
DNo laws since automated systems are neutral

Explanation

Automated underwriting systems that use geographic criteria (like zip codes) as a proxy for protected characteristics may violate both the Fair Housing Act (housing finance) and ECOA (credit decisions). Modern fair lending law recognizes that facially neutral criteria that have a disparate impact on protected classes may be illegal. Federal regulators examine lenders' underwriting criteria for potential discriminatory effects.

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