September 29, 2018
On September 28, the Connecticut Department of Banking issued a memorandum announcing its no-action position regarding one section of HB 5490/Public Act 18-173. That section requires sales finance companies to acquire and maintain adequate records of the ethnicity, race, and sex of any applicant or co-applicant for a retail installment contract, beginning October 1, 2018. The memo states that the DOB has asked the Bureau of Consumer Financial Protection for an official interpretation as to whether this new requirement is consistent with Regulation B, which implements the Equal Credit Opportunity Act. The memo further notes that until the DOB receives additional guidance from the BCFP, it will take a no-action position as to the enforcement of the new requirement.