What happened

On October 22, 2021, the CFPB and Justice Department sued Trustmark National Bank, headquartered in Jackson, Mississippi, alleging that from 2014 through 2018 it redlined majority-Black and Hispanic neighborhoods in the Memphis MSA—avoiding mortgage credit needs there in violation of the Fair Housing Act, ECOA, and the CFPA. The OCC joined the resolution. Those are allegations. The court entered a consent order on October 27, 2021. There was no trial verdict on the merits.

Trustmark’s 8-K said the package included a $5 million civil money penalty ($4 million OCC, $1 million CFPB) and a $3.85 million loan subsidy fund to increase credit in majority-Black and Hispanic neighborhoods, plus other outreach. Ordered restitution-style lending subsidies are not a gift. In May 2025, CFPB records, the agencies moved to terminate the order and the court vacated the 2021 judgment. That update means the order ended after the money terms were met. It is not an exoneration of the original redlining claims.

The Cookout read

Mixed. A federal redlining case aimed at majority-Black Memphis neighborhoods is a serious fair-housing file, even when Hispanic tracts are in the same caption. The subsidy fund is labeled as what the consent order required. Do not treat a 2025 termination as a rewrite of 2014–2018, and do not relabel penalty-and-subsidy dollars as charity.