Connecticut Announces No Action Position on Collection of Race Data Following AFSA Letter

On September 28, the Connecticut Department of Banking issued a memo announcing a no action position regarding Section 97 of HB 5490/Public Act 18-173, which amended state law to require sales finance companies to collect and maintain records of the ethnicity, race and sex of applicants and co-applicants for retail installment contracts starting October 1. The Department’s memo states that the Department has formally requested that the Bureau of Consumer Financial Protection (BCFP) provide an official interpretation as to whether the state’s requirements are consistent with Regulation B. The memo indicates that the no action position will remain until the Department receives further guidance from the BCFP.


AFSA met with the Department in August to raise concerns that the new law’s requirements were in conflict with Regulation, which generally prohibits creditors from collecting such data from credit applicants. AFSA followed up with the Department in a comment letter and requested a no action position on the issue.


AFSA will continue to monitor issue and keep members apprised of any updates from the Connecticut Department of Banking or the BCFP.