Disparate Impact & Enforcement Rollbacks: What’s the Tea in L&E?
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In the wake of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), the federal banking agencies have issued joint guidance to provide clarity on supervisory expectations for banks that...more
Key Takeaways: The OCC has removed references to “disparate impact” from its Fair Lending Handbook, consistent with the broader shift in federal enforcement philosophy under the current administration....more
The Office of the Comptroller of the Currency (“OCC”) has formally revised its fair lending examination procedures, announcing in Bulletin 2025-16, issued on July 14, 2025, that it has eliminated all references to disparate...more
On July 14, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2025-16, announcing the removal of references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and...more
On September 18, 2023, the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly published and sought comments on a proposal to implement new, standardized capital...more
Last week, the Office of the Comptroller of the Currency (“OCC”), Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), and the Consumer Financial...more
At the beginning of his term, President Biden declared that his administration would make it a policy to eliminate “racial bias and other forms of discrimination in all states of home-buying and renting.”...more
In the News. The Securities and Exchange Commission (SEC) adopted final rules to update and expand the statistical disclosures that bank and savings and loan registrants must provide to investors for the first time in 30...more
Federal Reserve Announces Plan for Real-Time Payment and Settlement Service - The Federal Reserve has announced that the Federal Reserve Banks will develop a new real-time gross settlement service with integrated clearing...more
The American Bankers Association has sent a letter to the DOJ, Fed, OCC, FDIC, HUD and CFPB requesting confirmation “in interagency guidance, updated exam procedures, and where appropriate amended regulations that the...more
A lawsuit was recently filed alleging that the U.S. Department of Treasury (Treasury) and Office of Comptroller of the Currency (OCC) perpetuated racial segregation in the City of Dallas in their administration of the Low...more