Fair Housing

In Washington, a lender who uses an automated underwriting system that produces discriminatory results may be liable under:

AOnly ECOA, not the Fair Housing Act
BThe disparate impact theory under both ECOA and the Fair Housing Act, even if the system was not intentionally discriminatory✓ Correct
CNo fair lending law because automated systems are neutral
DOnly criminal fraud statutes

Explanation

Even neutral-seeming automated underwriting systems can produce disparate impact discrimination if they disproportionately deny credit to protected class members. Both ECOA and the Fair Housing Act apply to lending, and intent is not required for disparate impact liability.

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