 FDIC Policy Statement, p. 5399 (April 29, 2004).In addition to ECOA and FHA, the Civil Rights Act of 1966, as amended, provides that "[a]ll citizens of the United States shall have the same right, in every State and Territory, as is enjoyed by white citizens thereof to inherit, purchase, lease, sell, hold, and convey real and personal property".42 U.S.C.