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You are here: Home / PRRAC Update / PRRAC Update: Cavalier CFPB rulemaking approach; Massachusetts rent control brief; HUD comments (April 30, 2026)

PRRAC Update: Cavalier CFPB rulemaking approach; Massachusetts rent control brief; HUD comments (April 30, 2026)

April 30, 2026 by

CFPB Publishes Final Rule Undermining the Equal Credit Opportunity Act through Cavalier Approach to the Rulemaking Process: On April 22, 2026, the Consumer Financial Protection Bureau (CFPB) published a final rule that is substantially similar to a November 2025 proposed rule regarding the Equal Credit Opportunity Act (ECOA) that was discussed in detail in the Update. The rule is scheduled to take effect on July 21, 2026 and would do damage in three distinct areas. First, it takes the position – contrary to clear legislative history and text that Congress crafted to mirror Title VII of the Civil Rights Act of 1964 – that ECOA does not authorize disparate impact claims. Second, it asserts that certain actions – which are generally examples of intentional discrimination, rather than disparate impact – that discourage credit applications do not violate the law. Third, it reverses the CFPB’s prior position – including during the first Trump Administration – with respect to special purpose credit programs in such a manner as to make it virtually impossible to use that vital tool to remedy the racial wealth gap.

In addition to the substantive and legal flaws with the final rule, the CFPB and the Office of Information and Regulatory Affairs (OIRA) at the Office of Management and Budget (OMB) handled the rulemaking process in an extremely cavalier fashion that betrayed a total disregard of norms. First, the CFPB only allowed 30 days for public comment, despite the complex and controversial nature of the rule. Second, the CFPB took a mere three and a half months to – allegedly (and implausibly) – review at least 64,518 comments posted on the Regulations.gov website. This occurred at a time when it is well known that the CFPB’s staff capacity has been eviscerated. Third, OIRA only took three and a half weeks to review the CFPB’s final rule. Lastly, OIRA pressed forward with approving the final rule despite the existence of requests by advocates, including PRRAC, for Executive Order 12,866 meetings that had yet to be scheduled. This rulemaking is far from the only example of this Administration’s disregard for the administrative process, but it is a stark one.

PRRAC Files Amicus Brief on Rent Control in the Massachusetts Supreme Judicial Court: On April 17, 2026, PRRAC, with the assistance of local counsel from Community Legal Aid filed an amicus brief in support of the certification of Initiative Petition 25-21, which, if enacted by the voters, would provide for statewide rent control in the Commonwealth of Massachusetts. Landlords had brought suit trying to keep the initiative off the ballot, in part by arguing speciously that such a statewide rent control law would violate the Takings Clause of the Fifth Amendment of the U.S. Constitution. PRRAC’s amicus brief highlighted how similar rent control regimes have coexisted with well-functioning housing markets, how multifamily lenders do not underwrite mortgages with an expectation of rent increases that would exceed the limits envisioned in the initiative, and how rent control advances racial justice. PRRAC partner Homes for All Massachusetts is playing a key role in leading the campaign to pass the initiative.

Other news and resources

PRRAC Submits Comments on HUD Mixed-Status Proposed Rule: On April 21, 2026, PRRAC submitted its comment letter in opposition to the proposed rule from the U.S. Department of Housing and Urban Development (HUD) that would, if it goes into effect, prevent families with mixed immigration status (such as a household including both citizens and individuals with Temporary Protected Status) from residing in certain federally-assisted housing with prorated subsidy.

New Study Highlights Successes of the Baltimore Regional Housing Partnership: Dionissi Aliprantis and PRRAC Social Science Advisory Board (SSAB) member Stefanie DeLuca have published a paper documenting how the Housing Choice Voucher mobility counseling efforts of the Baltimore Regional Housing Partnership have broken through persistent patterns of racial segregation.

New Urban Institute Research on the Impact of Large Upzonings on Housing Supply: Update readers may be interested in a new report from authors Yipeng Su, Will Curran-Groome, and PRRAC SSAB member Yonah Freemark on the impact of large upzonings on housing supply.

A Break from the Parade of Horribles – Valuing Hampshire College: Our stalwart National Coalition on School Diversity Director Gina Chirichigno is a proud alum of Hampshire College. The school is going through a tough time right now, with serious threats of near-term closure. At PRRAC, we value the school and its unique legacy. To give Hampshire its flowers, here are our team’s favorite alumni (leaving aside the obvious choice of Gina):

  • Audrey: Ken Burns
  • Tessa: Lupita Nyong’o
  • Thomas: the late Elliott Smith, whose songs will forever be etched into my consciousness

Filed Under: PRRAC Update

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PRRAC Updates

PRRAC Update: Cavalier CFPB rulemaking approach; Massachusetts rent control brief; HUD comments (April 30, 2026)

PRRAC Update: Major win in Virginia SOI case; Kansas preemption setback; HUD mixed-status comment deadline (April 16, 2026)

PRRAC Update: new version of Appendix B; challenge to HUD guidance; CLE opportunity (April 2, 2026)

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The Poverty & Race Research Action Council (PRRAC) is a civil rights law and policy organization based in Washington, D.C. Our mission is to promote research-based advocacy strategies to address structural inequality and disrupt the systems that disadvantage low-income people of color. PRRAC was founded in 1989, through an initiative of major civil rights, civil liberties, and anti-poverty groups seeking to connect advocates with social scientists working at the intersection of race and poverty…Read More

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