Welcome to the Compliance Cohort. We are a group of compliance professionals working to make compliance easier. Our goal is to take complex compliance concepts and put them in simple terms that apply to the real world. We are glad you have found us and look forward to collaborating in the future.
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All in Fair Lending
In this Compliance Clip (video), Adam explains a number of ways the examiners may identify redlining in an organization. In addition, he breaks down the different types of comparative evidence and overt evidence that could result in redlining. This video provides a great framework for understanding how redlining could appear in your financial institution.
On September 4, 2025, the NCUA announced its removal of all references to disparate impact liability from its Fair Lending Guide and other issuances. These updates are in line with the White House Executive Order 14281, which aims to restore equality of opportunity and meritocracy by directing federal agencies to remove the use of disparate impact liability across all contexts.
On August 29, 2025, the FDIC updated sections of the Consumer Compliance Examination Manual. The manual was updated to reflect that the FDIC will evaluate potential discrimination under the Equal Credit Opportunity Act and Fair Housing Act only through evidence of disparate treatment.
On July 14, 2025, the OCC announced that it has removed references to supervising banks for disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and has started removing references in other issuances. Concurrently, the OCC has instructed its examiners that they should no longer examine for disparate impact.
On July 10, 2025, the HUD and the OMB announced the termination of “burdensome” policies introduced under the Property Appraisal and Valuation Equity (PAVE) task force. The PAVE task force is an interagency group of 13 federal agencies formed during the Biden administration to address alleged discrimination in the appraisal process.
On June 12, 2025, Reuters reported that a federal judge in Chicago refused to allow the CFPB to vacate a racial discrimination settlement reached last year with Townstone Financial. The court found that there was no basis for granting an extraordinary request.
In this Compliance Clip (video), Adam explains what redlining is. In particular, Adam discusses the different definitions provided by the regulators as well as the different forms of redlining. A transcript of this video is now available.
On April 8, 2025, the OCC issued a Bulletin to inform banks of the appropriate names and addresses for notices required by the CRA and ECOA and for posters required by the FHA. Banks must implement the necessary changes within 90 days of the bulletin's issuance date.
On March 26, 2025, the CFPB announced that it is seeking to vacate the settlement the CFPB extracted from Townstone back in 2024 after suing the nonbank retail-mortgage creditor for discriminatory lending practices and redlining. In its press release, the CFPB stated that after a thorough review, the Bureau is seeking to “make Townstone whole by returning the six-figure penalty they were forced to pay.”
On January 17, 2025, the CFPB published a blog post authored by Appraisal Subcommittee (ASC) Chairman Zixta Martinez to provide an informal report on the progress made by the Subcommittee. In particular, Martinez provided updates in relation to the priorities set by the ASC back in April 2022.
