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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

Bureau of Consumer Financial ) 

Protection, ) Case No. 1:20-cv-04176 

 ) 

 Plaintiff, ) 

 ) 

v. ) 

 ) 

 ) 

Townstone Financial, Inc. and ) 

Barry Sturner, ) 

 ) 

 Defendants. ) 

AMENDED COMPLAINT 

 The Bureau of Consumer Financial Protection (“Bureau”) files this Amended 

Complaint against Townstone Financial, Inc. (“Townstone”) and Barry Sturner 

(“Sturner”) and alleges as follows. 

INTRODUCTION 

1. The Bureau brings this action under the Equal Credit Opportunity Act 

(“ECOA”), 15 U.S.C. §§ 1691–1691f; the Consumer Financial Protection Act of 2010 

(“CFPA”), 12 U.S.C. § 5536(a)(1)(A); and Federal Debt Collection Procedure, 28 

U.S.C. §§ 3301–3308. 

2. ECOA and its implementing regulation, Regulation B, 12 C.F.R. pt. 

1002, make it illegal for a creditor to discriminate against an applicant in any aspect of 

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a credit transaction on the basis of, among other characteristics, race, color, or 

national origin. 15 U.S.C. § 1691(a); 12 C.F.R. § 1002.4(a). ECOA and Regulation B 

prohibit any acts or practices that would discourage on a prohibited basis an applicant 

or prospective applicant from applying for credit. 15 U.S.C. § 1691(a); 12 C.F.R. 

§ 1002.4(b); 12 C.F.R. pt. 1002, Supp. I, 1002.4(b)(1) (“In keeping with the purpose of 

the Act—to promote the availability of credit on a nondiscriminatory basis—

§ 1002.4(b) covers acts or practices directed at prospective applicants that could 

discourage a reasonable person, on a prohibited basis, from applying for credit.”). 

3. Regulation B also provides that “prohibited basis” in ECOA includes 

“the characteristics of individuals with whom an applicant is affiliated or with whom 

the applicant associates,” such as “the race of other residents in the neighborhood 

where the property offered as collateral is located.” 12 C.F.R. pt. 202, Supp. I, 

202.2(2)(z). 

4. Since January 1, 2014, Townstone has been a non-depository mortgage 

lender or mortgage broker exclusively engaged in mortgage lending.1

 Townstone has 

acted as a correspondent lender for the majority of its business and also has brokered 

Federal Housing Administration and Veterans Administration home loans. From at 

least 2014 through 2017, Townstone ranked in the top 10% of lenders that drew 

1

 For purposes of this Complaint, “mortgage loans” refers to all loans that Townstone 

and other creditors were required to report under the Home Mortgage Disclosure Act 

(“HMDA”), 12 U.S.C. §§ 2801–2810, and “mortgage lending” refers to providing 

those loans. 

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applications from the Chicago-Naperville-Elgin Metropolitan Statistical Area 

(“Chicago MSA”). 

5. Since at least 2014, Townstone has engaged in unlawful discrimination, 

including redlining and acts or practices that would discourage prospective applicants, 

on the basis of race, from applying for credit in the Chicago MSA.

JURISDICTION AND VENUE 

6. This Court has subject-matter jurisdiction over this action because it is 

brought under “Federal consumer financial law,” 12 U.S.C. § 5565(a)(1); presents a 

federal question, 28 U.S.C. § 1331; and is brought by an agency of the United States, 

28 U.S.C. § 1345. 

7. Venue is proper in this district because both Townstone and Sturner are 

located, reside, and do business in this district. 12 U.S.C. § 5564(f). 

8. The Bureau is an independent agency of the United States created by the 

CFPA. 12 U.S.C. § 5491(a). The Bureau has independent litigating authority, including 

the authority to enforce the CFPA and ECOA. 12 U.S.C. §§ 5564(a)–(b), 5481(12)(D), 

(14). 

9. Townstone is incorporated in the State of Illinois and headquartered in 

Chicago. Townstone operates in five states—Illinois, Indiana, Michigan, Wisconsin, 

and Florida—with most of its mortgage lending and brokering in the Chicago MSA. 

10. Townstone is subject to the federal laws governing fair lending, 

including ECOA and its implementing regulation, Regulation B. 

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11. Townstone is a “creditor” under ECOA. 15 U.S.C. § 1691a(e). 

12. Townstone is a “covered person” under the CFPA. 12 U.S.C. 

§ 5481(6)(A) & (15)(A)(i).

13. Sturner is an Illinois resident and Townstone’s cofounder, sole owner, 

and sole director. Sturner serves as Townstone’s President and Chief Executive 

Officer, and he is also a loan officer. Sturner is a first transferee of all or almost all of 

Townstone’s liquid assets. 

FACTUAL ALLEGATIONS 

14. Townstone has acted to meet the credit needs of majority-white 

neighborhoods in the Chicago MSA while avoiding the credit needs of majority- and 

high-African-American neighborhoods. 

15. A majority-African-American neighborhood or area is a census tract in 

which more than 50% of the residents are identified in the U.S. Census as either Black 

or African American. A high-African-American neighborhood or area is a census tract 

in which more than 80% of the residents are identified in the U.S. Census as either 

Black or African American. 

16. The Chicago MSA comprises 14 counties in three states: Cook County, 

DuPage County, Grundy County, Kendall County, McHenry County, Will County, 

DeKalb County, Kane County, and Lake County, Illinois; Jasper County, Lake 

County, Newton County, and Porter County, Indiana; and Kenosha County, 

Wisconsin. 

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17. As of 2010, the Chicago MSA included about 1.6 million AfricanAmerican residents. 

18. As of 2010, the Chicago MSA’s population was 9,461,105, of which 17% 

were African Americans. According to the U.S. Census Bureau, 30.1% of the 

residents of the City of Chicago were African Americans. 

19. As of 2010, 18.7% of the Chicago MSA’s 2,215 census tracts were 

majority-African-American, and 13.8% were high-African-American. 

20. From 2014 through 2017, Townstone drew about 2,700 mortgage-loan 

applications from and originated about 1,800 mortgage loans in the Chicago MSA. 

21. From 2014 through 2017, Townstone drew over 90% of its mortgageloan applications for properties within the Chicago MSA. 

Townstone’s Marketing 

22. Since at least 2014, Townstone has engaged in acts or practices directed 

at prospective applicants that, together and separately, would discourage prospective 

applicants, on the basis of race, from seeking or obtaining credit for properties within 

the Chicago MSA. 

23. Townstone’s business model has been to market and draw mortgageloan applications primarily through radio advertising. 

24. Starting at least as early as 2014, Townstone has marketed through “The 

Townstone Financial Show,” its own radio show and podcast. 

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25. Townstone has generated up to 90% of its mortgage-loan applications 

from radio advertising, including through the Townstone Financial Show. 

26. The Townstone Financial Show is a long-form commercial 

advertisement, which Townstone refers to as an infomercial, that also includes shorter 

advertisements for Townstone during commercial breaks. Since 2014, the Townstone 

Financial Show hosts have discussed mortgage-related issues on the show and have 

taken questions from prospective applicants. The hosts have regularly referred to their 

work at Townstone and promoted the benefits that prospective applicants might 

expect from applying for mortgage loans from Townstone. 

27. Since about January 2015, the Townstone Financial Show has been cohosted by Sturner and another senior loan officer. 

28. Townstone’s website and the Townstone Financial Show have described 

the hosts of the Townstone Financial Show as “Chicago real-estate experts.” 

29. Starting at least as early as 2014, the Townstone Financial Show was 

conducted weekly on AM radio and reached the entire Chicago MSA. A weekly 

podcast of the radio show has been available exclusively online. Townstone Financial 

Show radio broadcasts and podcasts have been available on the Townstone website. 

Both the radio show and podcast have been streamed on Facebook Live and then 

advertised on Facebook, Twitter, and LinkedIn. 

30. The hosts have typically started the Townstone Financial Show podcasts 

by stating Townstone’s licensing information, including that Townstone is a licensed 

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mortgage broker/banker, NMLS number 136639, Illinois residential-mortgage 

licensee number 6629. 

31. The Townstone Financial Show radio broadcasts have typically included 

an introductory statement such as: “This show is brought to you by Townstone 

Financial, the home-loan expert since 2002. Townstone Financial is an Indiana, 

Michigan, Wisconsin, Florida, Illinois mortgage licensee 6629, NMLS 136639. 

Remember no one values your mortgage business more than Townstone Financial.” 

32. The Townstone Financial Show has regularly included statements that 

would discourage African-American prospective applicants from applying for 

mortgage loans, or making or pursuing an application, including from Townstone; 

would discourage prospective applicants living in majority- or high-African-American 

neighborhoods from applying for mortgage loans, or making or pursuing an 

application, including from Townstone; and would discourage prospective applicants 

from applying for mortgage loans, or making or pursuing an application, for 

properties in majority- or high-African-American neighborhoods, including from 

Townstone. 

33. For example, during a January 2014 broadcast in which Townstone 

marketed its services, a caller from Markham, Illinois, asked how he and his wife 

could improve their credit scores. Markham is a city in Cook County, Illinois, and its 

population is 80.3% African American, according to the U.S. Census Bureau. 

Referring to the women of this predominately African-American area, the Townstone 

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Financial Show’s host responded that “[you’ve] got to keep those women in line over 

there in Markham.” The host went so far as to presume that the caller should “stop 

spending freaking money [on his wife] and tell her to get a better job.” While 

discussing the couple’s credit concerns, the host turned his comments toward 

Markham generally, claiming that “it’s crazy in Markham on weekends” and stating, “I 

know, I’ve been to Markham.” “You drive very fast through Markham,” he 

continued, “and you don’t look at anybody or lock on anybody’s eyes in 

Markham . . . . You look at your dashboard, you don’t lock on anybody.” 

34. In another January 2014 broadcast of the Townstone Financial Show, 

during which Townstone marketed its services, Townstone’s then-president 

encouraged listeners that “it’s a great time to buy, it’s a great time to rent, it’s a great 

time to sell.” The show’s hosts, including a local realtor and a bankruptcy attorney, 

then recommended that listeners preparing a home for sale should “take down the 

Confederate flag.” 

35. In a June 2016 episode of the Townstone Financial Show, during which 

Townstone marketed its services, before discussing the mortgage-lending services that 

Townstone could provide to police officers and others, Sturner volunteered his view 

of the South Side of Chicago. The South Side refers to the southern neighborhoods in 

the City of Chicago and is majority-African-American, with about 489,000 African 

American or Black residents. According to Sturner, that part of the city between 

Friday and Monday is “hoodlum weekend,” and the police are “the only ones between 

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that [area] turning into a real war zone and keeping it where it’s kind of at.” 

36. In a January 2017 episode of the Townstone Financial Show, during 

which Townstone marketed its services, the hosts discussed a now-replaced grocery 

store in downtown Chicago that was part of the Jewel-Osco grocery-store chain. 

Sturner described “[having] to go to the Jewel on Division,” which he referred to as 

“Jungle Jewel.” Sturner described the “Jungle Jewel” as “a scary place,” attributing his 

fear and the store’s nickname to the “Jungle Jewel’s” patrons who “packed” the store 

and “were people from all over the world.” 

37. In a November 2017 episode of the Townstone Financial Show, during 

which Townstone marketed its services, Townstone’s senior loan officer discussed a 

recent skydiving experience and the ensuing “rush” from the jump; another 

Townstone host responded that he thought skydiving was crazy and suggested that 

someone “walking through the South Side at 3AM [would] get the same rush.” 

38. Through the Townstone Financial Show, Townstone has characterized 

areas and people in a manner that would discourage those who identify or associate 

with those areas or people from applying for credit. For example, the Townstone 

Financial Show’s hosts have disparaged majority-African-American areas as “hoodlum 

weekend” and approaching “a real war zone” or as “crazy” and places “to be driven 

through quickly” while avoiding eye contact; they have referred to a place with 

“people from all over the world” as a “jungle” and “scary”; they have disparaged the 

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women of a predominantly African-American area; and their home-selling advice has 

included recommendations regarding displays of the Confederate flag. 

39. A prospective applicant is reasonable to consider statements made by 

loan officers, realtors, and others marketing themselves as real-estate experts when 

making decisions about a property or seeking credit. And a reasonable prospective 

applicant would consider the characteristics of prospective neighborhoods, including 

the neighborhoods’ safety or dangerousness, when making decisions about a property 

or seeking credit. 

40. Even though African Americans made up 30% of the population of the 

City of Chicago, Townstone has not targeted any marketing toward African 

Americans in the Chicago MSA. 

41. Townstone has engaged in unlawful conduct by engaging in acts or 

practices that would discourage African-American prospective applicants from 

applying for mortgage loans, or making or pursuing an application, including from 

Townstone; would discourage prospective applicants living in majority- or highAfrican-American neighborhoods from applying for mortgage loans, or making or 

pursuing an application, including from Townstone; and would discourage 

prospective applicants from applying for mortgage loans, or making or pursuing an 

application, for properties in majority- or high-African-American neighborhoods, 

including from Townstone. 

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Applications from African-American Neighborhoods 

42. Based on HMDA data from 2014 through 2017, Townstone received an 

average of 740 mortgage-loan applications each year. Townstone brokered an average 

of 60 total Federal Housing Administration and Veterans Administration home loans 

each year. 

43. Townstone has drawn few applications from African-American 

applicants throughout the Chicago MSA. From 2014 through 2017, Townstone drew 

about 2,700 applications, of which only 37 (1.4%) came from African Americans in 

the Chicago MSA. During the same period, other mortgage lenders in the Chicago 

MSA drew 1,217,223 applications, of which 119,370 (9.8%) came from AfricanAmerican applicants. 

44. Similarly, from 2014 through 2017, Townstone drew almost no 

applications from applicants applying for mortgage loans for properties in majorityAfrican-American neighborhoods. During the same period, Townstone drew an 

average of five or six applications each year (0.8%, 0.8%, 0.7%, and 0.9% of all 

Townstone applications) for properties in high-African-American neighborhoods, 

even though such neighborhoods made up 13.8% of the Chicago MSA’s census tracts. 

Of Townstone’s five or six applications each year for properties in high-AfricanAmerican neighborhoods (more than 80% African American), more than half each 

year were from non-Hispanic white applicants. 

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45. Similarly, only 2.3%, 1.4%, 1.4%, and 2.2% of Townstone’s applications 

for the years 2014 through 2017, respectively, came from applicants applying for 

mortgage loans for properties in majority-African-American areas, even though 18.7% 

of the Chicago MSA’s census tracts were majority-African-American. 

46. Statistical analyses of Townstone’s mortgage-loan applications in the 

Chicago MSA, as compared to its peer lenders during the same period, show 

disparities between Townstone and its peers in drawing mortgage-loan applications 

for properties in African-American neighborhoods. 

47. These disparities are statistically significant and demonstrate that there 

were applicants seeking mortgage loans for properties in African-American 

neighborhoods in the Chicago MSA from Townstone’s peers in much higher 

proportions than from Townstone. 

48. Townstone had no legitimate, non-discriminatory reason to draw 

relatively few applications for mortgage loans for properties in these majority-AfricanAmerican areas. 

49. Townstone drew a significantly smaller proportion of mortgage-loan 

applications for properties in majority-African-American neighborhoods than did its 

peer lenders operating in the Chicago MSA. While Townstone drew 2.3%, 1.4%, 

1.4%, and 1.3% of its applications for properties in majority-African-American 

neighborhoods from 2014 through 2017, respectively, Townstone’s peers drew many 

times more—8.2%, 7.6%, 7.7%, and 8.1%. 

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50. Similarly, Townstone drew a significantly smaller proportion of 

mortgage-loan applications for properties in high-African-American neighborhoods 

than its peers operating in the Chicago MSA. While Townstone drew only 0.8%, 

0.8%, 0.7%, and 0.9% of its applications for mortgage loans for properties in highAfrican-American census tracts from 2014 through 2017, respectively, other similar 

lenders drew 5.3%, 4.9%, 5.1%, and 5.5% of their applications from such census 

tracts—6.3, 6.2, 7.7 and 6.1 times that of Townstone. 

51. Townstone employed 17 loan officers from 2014 through 2017. 

Townstone did not employ an African-American loan officer during that period, even 

though it was aware that hiring a loan officer from a particular racial or ethnic group 

could increase the number of applications from members of that racial or ethnic 

group. 

52. Townstone’s hiring practices, consumer outreach, consumer 

interactions, and other business acts or practices exclude or treat differently AfricanAmerican prospective applicants for credit, as well as prospective applicants for credit 

in African-American census tracts. 

COUNT 1: ECOA VIOLATIONS—TOWNSTONE 

53. The Bureau incorporates the allegations in Paragraphs 1–52 here by 

reference. 

54. Townstone’s acts or practices would discourage from seeking credit, on 

the basis of race or the racial composition of neighborhoods, African-American 

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prospective applicants, as well as those who identify or associate with, and those 

seeking credit in, majority- and high-African-American neighborhoods in the Chicago 

MSA. 

55. Townstone’s discouragement on the basis of race constitutes unlawful 

discrimination in violation of Regulation B and ECOA. 15 U.S.C. § 1691 et seq.; 

12 C.F.R. § 1002.4(b). 

56. Townstone’s acts or practices discriminate against African-American 

prospective applicants, as well as those seeking credit in majority- and high-AfricanAmerican neighborhoods in the Chicago MSA. 

57. Townstone’s discrimination with respect to credit transactions on the 

basis of race or the racial character of neighborhoods within the Chicago MSA 

violates ECOA. 15 U.S.C. § 1691 et seq. 

58. Townstone’s conduct constitutes a pattern or practice of discrimination 

and discouragement, in violation of ECOA. 15 U.S.C. § 1691 et seq. 

COUNT 2: CFPA VIOLATIONS—TOWNSTONE 

59. The Bureau incorporates the allegations of Paragraphs 1–52 here by 

reference. 

60. Section 1036(a)(1)(A) of the CFPA prohibits a covered person from 

offering or providing to a consumer any financial product or service not in 

conformity with “Federal consumer financial law” or otherwise committing any act or 

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omission in violation of a “Federal consumer financial law.” 12 U.S.C. 

§ 5536(a)(1)(A). 

61. Townstone’s ECOA violations, described above in Count 1, constitute 

violations of § 1036(a)(1)(A) of the CFPA. 12 U.S.C. § 5536(a)(1)(A); 15 U.S.C. § 

1691c(b). 

COUNT 3: FRAUDULENT TRANSFER—STURNER 

62. The Bureau incorporates the allegations of Paragraphs 1–52 here by 

reference. 

63. Townstone transferred more than $2.4 million to Sturner in December 

2018 and January 2019 (“the Transfer”). 

64. After the Transfer, Townstone was insolvent or soon became insolvent. 

65. After the Transfer, Townstone had no cash. 

66. After the Transfer, Townstone had less than $100,000 worth of liquid 

assets. 

67. After the Transfer, Townstone retained possession or control of the 

transferred money. 

68. Townstone and the Bureau had discussed the Bureau’s potential suit in 

the months preceding the Transfer. 

69. Townstone did not receive reasonably equivalent value from Sturner for 

Townstone’s $2.4 million. 

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70. Townstone did not receive anything of value from Sturner for 

Townstone’s $2.4 million. 

71. Sturner made the decision on Townstone’s behalf for Townstone to 

transfer $2.4 million to Sturner. 

72. Townstone and Sturner engaged in the Transfer with actual intent to 

hinder, delay, or defraud the Bureau. 

73. When Townstone and Sturner engaged in the Transfer, Townstone 

believed, or reasonably should have believed, that it would incur a debt to the Bureau 

beyond Townstone’s ability to pay. 

74. When Townstone and Sturner engaged in the Transfer, Townstone and 

Sturner believed or reasonably should have believed that Townstone would incur a 

debt to the Bureau greater than the value of Townstone’s remaining liquid assets. 

75. When Townstone and Sturner engaged in the Transfer, Townstone and 

Sturner believed or reasonably should have believed that Townstone would incur 

other financial obligations beyond Townstone’s ability to pay, including payroll, taxes, 

property rental, utility costs, marketing costs, and legal costs. 

76. After Townstone and Sturner engaged in the Transfer, Sturner paid 

Townstone’s bills. 

77. After Townstone and Sturner engaged in the Transfer, Sturner paid 

Townstone’s bills using, at least in part, the money Sturner received in the Transfer. 

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78. Under 28 U.S.C. §§ 3301-3308, the Transfer was fraudulent as to the 

Bureau and as to any Townstone debt to the Bureau.

DEMAND FOR RELIEF 

The Bureau requests that the Court enter an order that: 

(1) declares that Townstone’s acts and practices constitute violations of 

ECOA, 15 U.S.C. §§ 1691–1691f; 

(2) requires Townstone, under 15 U.S.C. § 1691c(a)(9) and 12 U.S.C. 

§ 5565(a), as well as Townstone’s agents, employees, successors, and all others in 

active concert or participation with Townstone, to: 

a. not discriminate in any aspect of its mortgage-lending business on the 

basis of race or any other basis prohibited by ECOA, 15 U.S.C. § 1691(a); 

b. take such affirmative steps as may be necessary to restore, as nearly as 

practicable, the victims of Townstone’s unlawful conduct to the position they 

would have been in but for the discriminatory conduct; and 

c. take such affirmative steps as may be necessary to prevent the recurrence 

of any such discriminatory conduct; to eliminate, to the extent practicable, the 

effect of Townstone’s unlawful practices; and to implement policies and 

procedures to ensure that all prospective applicants have an equal opportunity 

to seek and obtain loans on a non-discriminatory basis and with nondiscriminatory terms and conditions; 

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(3) awards damages, restitution, equitable, and other monetary relief, under 

15 U.S.C. § 1691c(a)(9) and 12 U.S.C. § 5565; 

(4) assesses a civil money penalty against Townstone in an amount 

authorized by 12 U.S.C. § 5565(c); 

(5) declares that Townstone’s transfer of money to Sturner in December 

2018 and January 2019 was fraudulent under 28 U.S.C. §§ 3301-3308; 

(6) allows the Bureau to avoid the Transfer to the extent necessary to satisfy 

any monetary judgment entered in this case against Townstone; 

(7) compels Sturner to transfer to the Bureau, in a manner to be prescribed 

by the Bureau, all money transferred by Townstone to Sturner up to the amount 

necessary to satisfy any monetary judgment entered in this case against Townstone; 

(8) awards any other relief to the Bureau that is available under the law and 

necessary to restore the Bureau to the position it would have been upon entry of 

judgment in this case if Townstone and Sturner had not engaged in a fraudulent 

transfer; 

(9) awards to the Bureau the costs of bringing this action; and 

(10) awards to the Bureau such additional relief as the interests of justice may 

require. 

 

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 Respectfully submitted, 

THOMAS G. WARD 

Enforcement Director 

CARA PETERSEN 

Principal Deputy Enforcement Director 

JEFFREY PAUL EHRLICH 

Deputy Enforcement Director 

KARA K. MILLER 

Assistant Litigation Deputy 

/s/ Barry Reiferson. . . . . . . . . . . . . . . . . .,,,.

BARRY REIFERSON NY Reg. #4343893 

Email: barry.reiferson@cfpb.gov 

VINCENT HERMAN DC Bar #974596 

Email: vincent.herman@cfpb.gov 

MARY E. OLSON, IL ARDC 6297334 

Email: mary.olson@cfpb.gov 

MICHAEL G. SALEMI, IL ARDC 6279741 

Email: michael.salemi@cfpb.gov 

230 S. Dearborn Street 

Suite 1590 

Chicago, IL 60604 

 and 

1700 G Street, NW 

Washington, DC 20552 

Telephone: (202) 435-9599 

Attorneys for the Bureau of Consumer Financial Protection 

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