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

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.