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Landlords often deny a prospective tenant's lease application based on deficiencies in the tenant's credit report. It is unclear whether a landlord is required by federal statute to inform a rejected applicant of the specific reason his credit was deemed deficient. This Comment attempts to resolve this ambiguity in federal law by determining whether the Equal Credit Opportunity Act' ("ECOA") applies to leases. If the ECOA applies to leases, then landlords taking adverse action' on lease applications must inform applicants of the specific reasons their applications were denied. The answer to this question is important to the delicate balance between landlord and tenant protections because such information can be extremely valuable to tenants seeking to bring housing discrimination claims under the Fair Housing Act of 19683 and the Civil Rights Act of 1866. The Comment concludes that courts should resolve this issue by taking into account state law governing permissible terms of housing lease contracts in order to determine whether a given lease involves "defer[red] payment of debt," the necessary element of a "credit" transaction under the ECOA.5 This Comment focuses narrowly on whether the ECOA applies to residential housing leases, rather than leases of other sorts,6 for several reasons. First, because of the persistence and prevalence of housing discrimination,7 the issue of whether the ECOA applies in this particular

Application of the Equal Credit Opportunity Act to Housing Leases