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Lori Sommerfield

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With over two decades of consumer financial services experience in federal government, in-house, and private practice settings, and a specialty in fair lending regulatory compliance, Lori counsels clients in supervisory issues, examinations, investigations, and enforcement actions.

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This post was cited on July 13, 2026 in Briefs Finance, CNBC, and Mortgage Professional.

On May 19, President Donald Trump issued Executive Order 14406, “Restoring Integrity to America’s Financial System,” which establishes a new policy to safeguard financial institutions against structural credit risks and deter fraud and abuse. The order links illicit finance, immigration enforcement, and consumer credit risk, and directs federal financial regulators to tighten risk-based controls around non-work authorized populations and their employers. It reflects a policy view that even basic financial services, when offered without robust know-your-customer and due diligence, can facilitate terrorist financing, narcotics and human trafficking, and large-scale money laundering. At the same time, it expresses concern that lending to borrowers who lack work authorization or face a high risk of deportation may undermine safety and soundness because of heightened “ability-to-repay” concerns.

On May 27, the National Fair Housing Alliance (NFHA), Rise Economy (formerly known as the California Reinvestment Coalition), and two fair lending compliance companies (BLDS, LLC, and SolasAI) filed suit in the U.S. District Court for the District of Columbia challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau) Regulation B (Subpart A) final rule, which implements the Equal Credit Opportunity Act (ECOA), and was issued on April 22, 2026. The case, National Fair Housing Alliance et al. v. CFPB et al., is notable not only for challenging the CFPB’s significant rewrite of longstanding Reg B, but also because the NFHA and Rise Economy are the first consumer advocacy organizations to sue the CFPB over the final rule.

In this episode of The Consumer Finance Podcast, Chris Willis, Lori Sommerfield, Taylor Gess, and Lane Page discuss the CFPB’s sweeping final amendments to Subpart A of Regulation B. The group unpacks the elimination of the disparate impact legal theory from ECOA, the narrowing of the discouragement standard (including what it means for targeted advertising), and the significant new limits on special purpose credit programs (SPCPs). They also explore expected litigation challenges, the continuing role of the Fair Housing Act and state laws in bringing cases under the disparate impact theory, and the practical steps lenders should be taking now to reassess fair lending testing, SPCP design, and redlining risk in light of the final rule.

Yesterday, President Trump signed an Executive Order titled “Integrating Financial Technology Innovation into Regulatory Frameworks.” The Order directs federal financial regulators to review and streamline regulations, guidance, supervisory practices, and application processes that may impede financial technology (fintech) innovation and competition, and it asks the Federal Reserve to evaluate potential direct access to Reserve Bank accounts and services for uninsured depository institutions and certain non‑bank financial firms, including digital asset companies. The Order is the latest in a series of administration actions aimed at positioning the U.S. as a global leader in digital assets and financial technology.

On May 15, the Office of the Comptroller of the Currency (OCC) finalized two closely linked rules on mortgage escrow accounts that respond directly to the issues we discussed in our recent post, Second Circuit on Remand in Cantero: New York Escrow-Interest Law Is Preempted, Over a Vigorous Dissent. In that decision, the Second Circuit held that New York’s 2% interest‑on‑escrow statute is preempted as applied to national banks under the Barnett Bank standard, deepening a circuit split with the First and Ninth Circuits. The OCC’s new rules both adopt the Second Circuit’s view of the underlying bank powers and attempt to bring regulatory clarity to the interest‑on‑escrow preemption question for OCC‑regulated institutions nationwide.

Yesterday, California Governor Gavin Newsom announced the appointment of Rohit Chopra, former Director of the Consumer Financial Protection Bureau (CFPB) and former Federal Trade Commission (FTC) Commissioner, as Secretary of the state’s new Business and Consumer Services Agency (BCSA). The new cabinet‑level agency, which formally launches on July 1, 2026, is designed to consolidate and elevate state‑level consumer and market oversight at a moment when federal enforcement is being scaled back. Governor Newsom framed the move as bringing “one of the nation’s most prominent consumer protection leaders” into state government to crack down on corporate abuse, curb junk fees, and lower costs for Californians.

On May 5, Craig Trainor, Assistant Secretary for the Office of Fair Housing and Equal Opportunity (FHEO) at the U.S. Department of Housing and Urban Development (HUD), used the American Bankers Association’s Risk and Compliance Conference to send a clear message about how the Trump administration plans to enforce the Fair Housing Act (FHA) going forward, including with respect to how it will treat special purpose credit programs (SPCPs).

Today, the Consumer Financial Protection Bureau (CFPB or Bureau) released its final rule revising the 2023 small business lending data collection and reporting rule under the Equal Credit Opportunity Act (ECOA) and Regulation B, which implements Section 1071 of the Dodd-Frank Act (2026 Final Rule). The 2026 Final Rule will become effective 60 days after publication in the Federal Register, and the compliance date for initial data collection is January 1, 2028.

Recent reporting from the ABA Banking Journal and the American Banker describes a rapidly evolving restructuring of the Consumer Financial Protection Bureau (CFPB or Bureau) under the Trump administration, with significant implications for the agency’s future role and for regulated entities.

The U.S. Department of Justice (DOJ) has issued an interim final rule extending the compliance dates for its 2024 Americans with Disabilities Act (ADA) Title II website and mobile application accessibility regulations for state and local governments. This development is noteworthy for anyone watching the long‑running debate over web accessibility standards, as well as the potential implication of this rulemaking for a future DOJ proposed rule governing public accommodations under Title III of the ADA.