Illinois Enacts Disparate Impact Standard for Credit Decisions: What Lenders Need to Know

Introduction Illinois has joined a growing number of states that are expanding fair lending obligations at the state level even as the federal government moves in the opposite direction. On July 31, 2026, SB 3777 became Public Act 104-0744 , amending the Illinois Human Rights Act (Act) to prohibit not only intentional discrimination in lending and credit card issuance, but also the use of facially…