Compliance VIEWpoints-Issue 3-2024 November 2024 | Page 5

Citadel Credit Union Fair Lending Consent Order With the Department of Justice

On Oct . 10 , 2024 , Citadel Credit Union ( Citadel ), a $ 6 billion credit union in Pennsylvania , and the Department of Justice ( DOJ ) jointly submitted a consent order to settle claims of fair lending violations . The consent order spells out how Citadel engaged in redlining from at least 2017 through 2021 , and violated the Equal Credit Opportunity Act , Regulation B and Fair Housing Act . It is the first ever redlining settlement between the DOJ and a credit union .
Citadel ’ s Market Area
At the time of the consent order , Citadel was the 18th largest lender in its market area and the second in the greater Philadelphia area . Citadel ’ s field of membership is comprised of Bucks , Chester , Delaware , Montgomery and Philadelphia Counties in Pennsylvania , and the city of Lancaster . Since Citadel operates two branches and does significant lending in Lancaster County outside the city of Lancaster , the entire county is included in the credit union ’ s market . The market area has approximately 4.7 million residents , of which its population is comprised of 63 % White , 20 % Black , 9 % Hispanic or Latino , 6 % Asian and 2 % of other races .
Citadel ’ s target market area population is 71 % White , 24 % Black and Hispanic , and 5 % “ majority-minority .”
In Philadelphia County , the population contains 76 % of all majority Black and Hispanic tracts in the market area , which most of which are in Citadel ’ s market area . The majority of the Black and Hispanic population within Citadel ’ s market area lives in Philadelphia County .
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VIEWPOINTS : REGULATORY COMPLIANCE EDITION | 01