DOJ, CFPB, and OCC secured a combined $8.85 million consent order against Trustmark National Bank for deliberate redlining of majority-Black and Hispanic neighborhoods in Memphis, including a $4 million OCC civil penalty, $1 million CFPB penalty, and $3.85 million loan subsidy fund.

Trustmark National Bank — Deliberate Redlining of Black and Hispanic Neighborhoods in Memphis (2014–2016)

Outcome: DOJ, CFPB, and OCC secured a multiagency consent order totaling approximately $8.85 million, including a $4 million OCC civil penalty, $1 million CFPB civil penalty, and $3.85 million loan subsidy fund for affected communities. The case was announced October 22, 2021 as the first action under DOJ's new Combating Redlining Initiative.

Trustmark National Bank, headquartered in Jackson, Mississippi, was the subject of a triagency enforcement action announced on October 22, 2021 by the Department of Justice, the Consumer Financial Protection Bureau, and the Office of the Comptroller of the Currency. The action was based on the OCC's examination of Trustmark's lending activities from 2014 to 2016, which found that the bank deliberately denied residents of majority-minority and high-minority neighborhoods in Memphis equal access to mortgage loans.

The DOJ complaint alleged violations of the Fair Housing Act and the Equal Credit Opportunity Act. Regulators found that Trustmark's branches were concentrated in majority-white neighborhoods, that its loan officers did not serve the credit needs of majority-Black and Hispanic neighborhoods, and that the bank's outreach and marketing systematically avoided those communities. The OCC found that Trustmark's conduct amounted to deliberate discrimination within the meaning of the Fair Housing Act under 42 U.S.C. §§ 3604(a), (b), and 3605(a).

The OCC assessed a $4 million civil money penalty under 12 U.S.C. § 1818(i) for the Fair Housing Act violations. The CFPB's consent order required payment of a separate $1 million civil penalty. Under the DOJ-led settlement, Trustmark was required to invest $3.85 million in a loan subsidy program offering qualified applicants for credit secured by properties in majority-Black and Hispanic neighborhoods in Memphis loans on more affordable terms, and to open a new loan production office in a majority-minority neighborhood in the Memphis MSA.

This case was significant as the inaugural action under the DOJ's Combating Redlining Initiative, announced in conjunction with the settlement and signaling a coordinated multiagency crackdown on mortgage discrimination. The consent order was terminated early in May 2025.

Primary Source: CFPB Newsroom — Trustmark National Bank Action