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 impact liability from the “Fair Lending” section of the Comptroller’s Handbook.  This revision marks a major shift in how the federal agency supervises banks with respect to anti-discrimination laws.Continue Reading OCC Ends Use of Disparate Impact in Fair Lending Supervision

On Thursday, July 10, 2025, the U.S. Senate confirmed Jonathan Gould to serve as the next Comptroller of the Currency in a 50–45 vote.  Gould will succeed Acting Comptroller Rodney Hood, who offered his congratulations and praised Gould’s regulatory philosophy, stating that “Mr. Gould understands the critical importance of right-sizing regulations to be appropriately tailored, embracing innovation in the banking sector, and ensuring fair access to financial services.”  As Comptroller, Gould will also join the Board of Directors of the Federal Deposit Insurance Corporation, positioning him to influence interagency regulatory priorities.Continue Reading Jonathan Gould Confirmed as Comptroller of the Currency

Over the past two weeks, we have received numerous inquiries from financial institutions on what actions should be taken or considered to address the COVID-19/Coronavirus pandemic.  While every bank is different and the current situation is evolving each day, we have engaged in numerous discussions with banks on various strategies and considerations that are being reviewed or implemented during this uncertain time.
Continue Reading Coronavirus Update: Strategies and Considerations for Financial Institutions

This below article was originally posted on Vedder Thinking on June 4, 2019.

On Saturday, June 1, 2019, The Illinois General Assembly passed a bill (the “Diversity Disclosure Bill”) requiring most publicly held companies organized or headquartered in Illinois to include detailed demographic diversity information in their annual reports. Bill intended to provide data to