From settlements between the U.S. Department of Justice and lenders such as Citadel Federal Credit Union and City National Bank, which is NOT a common sanction included in settlement agreements?

• A. Monetary penalties, monitoring, and training
• B. Replacing the CEO with a person from a marginalized group
• C. Tax incentives for the company
• D. Zoning changes

Answer: (D)

Settlements with the DOJ for lending discrimination focus on remedies inside the lender’s operations to ensure compliance and prevent recurrence. The most typical tools are monetary penalties to incentivize change, independent monitoring to verify that reforms are carried out, and required training so employees understand and follow fair-lending laws. Zoning changes, however, are decisions about local land use and development, handled by city planning authorities rather than the bank’s internal operations or DOJ enforcement. They don’t fit the pattern of remedies aimed at correcting the lender’s practices, which is why they’re not a common sanction in these settlements. Leadership changes can appear in some cases as part of governance reforms, and tax incentives would be outside the standard remedy toolkit, but they don’t align as closely with the usual internal compliance-focused tools as monetary penalties, monitoring, and training do.