The Consumer Financial Protection Bureau has proposed to change its rules for the Equal Credit Opportunity Act, which requires fairness in lending, including mortgage lending. The revisions would eliminate use of disparate impact — the legal concept that conduct is discriminatory if it has inequitable effects, even if there was no intent to discriminate — and would revise provisions on discouragement of applicants or prospective applicants and on special purpose credit programs. HAC’s response argues that disparate impact is a necessary tool to identify discrimination in mortgage lending, including discrimination against rural residents.