News & Analysis as of

Regulatory Requirements Anti-Discrimination Policies Disparate Impact

Vorys, Sater, Seymour and Pease LLP

California Regulates the Use of AI in Employment Decisions

Effective October 1, 2025, California will join a growing number of jurisdictions that regulate the use of automated-decision systems (ADS) in employment decisions. Employers in California should review their use of ADS in...more

DCI Consulting

DOJ Releases Memo on Discrimination by Funding Recipients

DCI Consulting on

Late last month, the Department of Justice (DOJ) released a memorandum emphasizing that discrimination by recipients of federal funds will no longer be tolerated. Notably, this memo introduces the concept of "Unlawful Proxy...more

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

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

Blank Rome LLP

Changes to Civil Rights Enforcement: New Executive Order Eliminates Disparate-Impact Liability in Federal Regulations

Blank Rome LLP on

On April 23, 2025, the President issued an Executive Order (“EO”) titled “Restoring Equality of Opportunity and Meritocracy” that seeks to drastically curtail the use of disparate-impact liability in federal regulations,...more

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