Under ECOA, a creditor may decline a loan based on an applicant’s inability to repay, as demonstrated by verified income and other underwriting criteria. It is illegal to consider race, receipt of public assistance, or exercise of consumer rights as a basis for denial.

“A creditor may consider verified income in evaluating creditworthiness. Discrimination based on race, public assistance, or exercise of rights under the Consumer Credit Protection Act is prohibited.”

— 12 CFR § 1002.6, Regulation B (ECOA)