The Greenlining Institute’s Economic Equity and Telecommunications teams submitted a comment letter in response to the Consumer Financial Protection Bureau’s Trial Disclosure Program proposal. Greenlining raised that critical safeguards to control for discrimination and adverse impact were missing from this trial programĀ and that a lack of foresight to embed them could disproportionately harm consumers of color and others marginalized from financial markets. Greenlining raised the CFPB’s roll back of fair lending as an overarching concern for this trial program and the Bureau’s overall direction, and included questions and recommendations for the Bureau.