ALERT – CFPB Issues Fair Lending Law Interpretation Related to Use of AI in Credit Decisions

September 27, 2023

To our clients and friends:

On September 19, 2023, the Consumer Financial Protection Bureau issued Circular 2023-03 to address whether creditors could rely on stock reasons in the Bureau’s sample adverse action notices when issuing those notices after using AI in the credit decision. Our Alert discusses the CFPB’s interpretation of ECOA as it applies to the use of AI, the Bureau’s recent trend of announcing enforcement priorities through guidance, and steps to take to address the Circular’s key takeaways.

Our Alert is available here.



August 21, 2023

Washington, DC, August 21, 2023. For Immediate Release. Luse Gorman, PC is pleased to announce that Brendan Clegg has joined the Washington, DC law firm as a partner. Mr. Clegg was most recently at Alston & Bird LLP. With his addition to the partnership, Luse Gorman builds upon its unparalleled experience in the financial services industry, expanding and deepening its capabilities in regulatory and enforcement matters.


Alert – SEC Adopts Disclosure Rules on Cybersecurity Incidents, Risk Management, Strategy, and Governance

August 7, 2023

To our clients and friends:

The SEC recently approved amendments to Rule 10b5-1 regarding insider trading plans to revise the conditions that must be met for insiders to be able to use the 10b5-1 affirmative defense including, among other things, cooling-off periods, representations from plan participants and new periodic disclosure requirements for issuers and their insiders.

Our Alert regarding the new requirements is available here.


Luse Gorman is Legal Counsel to Harborstone Credit Union in its Proposed Acquisition of First Sound Bank

August 3, 2023

On August 1, 2023, Harborstone Credit Union, Lakewood, Washington, announced that it had entered into a purchase and assumption agreement to acquire substantially all the assets and assume substantially all the liabilities of First Sound Bank, Seattle, Washington. Following the completion of the acquisition, First Sound Bank will distribute the net transaction proceeds to its stockholders. The distribution to stockholders is estimated to be between $6.90 and $7.10 per share of First Sound Bank common stock, subject to adjustment based on a minimum equity target.


Luse Gorman Served as Legal Counsel to BV Financial, Inc. in its Conversion and Related $98.0 Million Stock Offering

August 2, 2023

On July 31, 2023, BV Financial, Inc., Baltimore, Maryland, the holding company for BayVanguard Bank, completed its conversion from the mutual holding company to the stock holding company form of organization and its related stock offering. A total of 9,798,980 shares of common stock were sold in the offering at a price of $10.00 per share. The Company’s common stock trades on the Nasdaq Capital Market under the symbol “BVFL.”