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Fair Lending › Disparate Impact › Office of the Comptroller of the Currency

Polsinelli

OCC Handbook Change is Latest Move in Administration’s Shift on Lending Discrimination

Polsinelli on

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

Vedder Price

OCC Ends Use of Disparate Impact in Fair Lending Supervision

Vedder Price on

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

Troutman Pepper Locke

In Response to President Trump’s Executive Order, the OCC Removes Disparate Impact References from Fair Lending Examination Manual

Troutman Pepper Locke on

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

Bilzin Sumberg

An Opportune Time For Financial Institutions to Review Their Fair Lending Procedures

Bilzin Sumberg on

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

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