In an earlier paper, we considered whether ISAs should be subject to federal consumer credit statutes, including the Truth in Lending Act ("TILA"), state licensed lender regimes, and usury laws in select states. We also considered whether ISAs should be subject to federal and select state credit discrimination statutes. In this paper, we consider the application of federal fair lending laws, select state equal access and credit anti-discriminations statutes, and broader educational anti-discrimination statutes.
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