HUD Proposes to Remove Disparate-Impact Liability Under Title VI

Adam Witmer
Regulatory Update, Fair Lending

On August 10, 2026, the HUD issued a supplemental notice of proposed rulemaking to remove provisions in HUD's Title VI implementing regulations that impose disparate-impact liability on recipients of HUD Federal financial assistance. This supplements the January 2026 proposed rule to remove HUD's disparate-impact regulations and leave interpretation of disparate-impact liability under the Fair Housing Act to the courts.

FinCEN Renews Minnesota GTO

Adam Witmer
Regulatory Update, BSA

On August 7, 2026, FinCEN renewed its Geographic Targeting Order (GTO) designed to combat fraud in Minnesota and protect U.S. taxpayers. In early January, the Agency issued a Geographic Targeting Order requiring all banks and money transmitters located in Hennepin County and Ramsey County, Minnesota, to file reports with FinCEN of certain international funds transfers of $3,000 or more. 

VIDEO: What Triggers Flood Compliance Requirements

VIDEO: What Triggers Flood Compliance Requirements

Adam Witmer
Flood

In this Compliance Clip (video), Adam explains the key events that trigger a financial institution's flood insurance compliance requirements. Learn when flood rules apply and why understanding these compliance triggers is essential for ensuring your institution meets its regulatory obligations. A transcript of this video is now available.

FDIC Launches New Office of Supervisory Appeals

Adam Witmer
Regulatory Update

On August 4, 2026, the FDIC announced the launch of a new Office of Supervisory Appeals (OSA) panel comprised of independent officials who will consider and resolve appeals of material supervisory determinations brought before the agency. The OSA is a standalone office within the FDIC and replaces the Supervision Appeals Review Committee as the final level of review of material supervisory determinations.

Paoletta Becomes CFPB Acting Director

Adam Witmer
Regulatory Update

On August 4, 2026, the Ballard Spahr reported that CFPB Deputy Director Mark Paoletta became the Bureau’s Acting Director following the expiration of Russell Vought’s service as Acting Director on August 1. Meanwhile, President Trump’s nominee to permanently lead the CFPB, Brian Johnson, is still awaiting Senate confirmation.

Agencies Issue Joint Proposal to Amend Community Reinvestment Act Rules

Adam Witmer
Regulatory Update, CRA

On July 31, 2026, the OCC and FDIC issued a joint proposal to amend parts of the Community Reinvestment Act (CRA). The proposed changes are intended to better align the regulations with the statutory mandate, help ensure community development activities benefit their intended communities, reduce burden particularly for community banks, and provide greater clarity on how banks can receive CRA consideration.

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