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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.
On January 17, 2025, the CFPB issued a special edition of its Supervisory Highlights concerning advanced technologies. In particular, the Winter 2025 Supervisory Highlights Edition looks at select examinations of institutions that use credit scoring models, including models built with advanced technology commonly marketed as AI/ML technology, when making credit decisions.
On November 1, 2024, the CFPB filed a proposed order to resolve its case against Townstone Financial for discriminatory lending practices and redlining African American neighborhoods in Chicago. The proposed order would prohibit Townstone from taking any actions that violate the Equal Credit Opportunity Act (ECOA) and require the company to pay a $105,000 penalty to the CFPB’s victims relief fund.
On October 15, 2024, the CFPB and the DOJ took action against Fairway Independent Mortgage Corporation for illegal mortgage lending discrimination against majority-Black neighborhoods in the greater Birmingham, Alabama area. According to the CFPB and DOJ, Fairway illegally redlined Black neighborhoods, including through its marketing and sales actions, by discouraging people from applying for mortgage loans in the Birmingham metropolitan area’s Black neighborhoods.
On September 18, 2024, the HUD announced the approval of a Conciliation Agreement with OceanFirst Bank for engaging in redlining by restricting access to credit and mortgage lending services in majority-Black, Hispanic, and Asian neighborhoods in the New Brunswick, New Jersey area. The HUD’s investigation was conducted alongside the DOJ after a referral from the OCC.
On July 15, 2024, the HUD charged multiple entities with housing discrimination for issuing a biased appraisal and then denying a refinance loan application in Denver, Colorado. HUD charged appraiser Maksym Mykhailyna, appraisal company Maverick Appraisal Group, appraisal management company Solidifi U.S. Inc. and lender Rocket Mortgage, LLC.
On July 17, 2024, the CFPB, FDIC, FHFA, FRB, NCUA, and OCC jointly issued a final rule, pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act, designed to help ensure the credibility and integrity of models used in valuations for certain mortgages secured by a consumer's principal dwelling. In particular, the rule will implement quality control standards for automated valuation models (AVMs) used by mortgage originators and secondary market issuers in valuing those homes.
On June 26, 2024, the CFPB released its Fair Lending Annual Report to Congress, describing the Bureau’s fair lending activities in enforcement, guidance and rulemaking, interagency coordination, and outreach and activities for calendar year 2023. Specifically. The Fair Lending Annual Report to Congress fulfills the Bureau’s statutory responsibility to report annually to Congress on public enforcement actions taken under the ECOA as well as the utility of the HMDA’s mortgage loan data collection requirements.
On May 13, 2024, the HUD announced that it has entered into a Conciliation Agreement with Rocket Mortgage, LLC resolving allegations that Rocket Mortgage denied a mortgage loan application based on race because the home being purchased was located within the Tribal boundaries of a federally recognized reservation.
In this Compliance Clip (video), Adam discusses what a protected class is under fair lending. In particular, Adam talks about the protected classes under the two fair lending laws: Fair Housing Act and ECOA., and how they differ as well as how they overlap. A transcript of this video is now available.
On February 12, 2024, the FFIEC on behalf of its member entities, issued a statement related to valuation discrimination and bias for member entities to consider in their consumer compliance and safety and soundness examinations. The statement provides principles for the examination of supervised institutions’ residential property appraisal and evaluation (valuation) practices to mitigate risks that may arise due to potential discrimination or bias in those practices, and to promote credible valuations.
On January 9, 2024, the OCC announced that it will host a public hearing of the Appraisal Subcommittee (ASC) on appraisal bias on February 13, 2024, from 10:00 a.m. to 1:00 p.m., at its headquarters at 400 7th Street SW, Washington, D.C.
On December 20, 2023, the CFPB and the DOJ sued Colony Ridge, a Texas-based developer and lender, for operating an illegal land sales scheme and targeting tens of thousands of Hispanic borrowers with false statements and predatory loans. The lawsuit alleges that Colony Ridge sells unsuspecting families flood-prone land without water, sewer, or electrical infrastructure, and that the company sets borrowers up to fail with loans they cannot afford.
On November 8, 2023, the CFPB ordered Citi to pay $25.9 million in fines and consumer redress for intentionally and illegally discriminating against credit card applicants the bank identified as Armenian American. According to CFPB Director Rohit Chopra, Citi purposefully discriminated against applicants of Armenian descent, primarily based on the spelling of their last name, and stereotyped Armenians as prone to crime and fraud. Chopra also said that Citi illegally fabricated documents to cover up its discrimination.
On October 24, 2023, the Federal Trade Commission and the State of Wisconsin took action against Wisconsin auto dealer group Rhinelander Auto Center, its current and former owners, and general manager Daniel Towne for deceiving consumers by adding illegal junk fees onto car prices. In addition, the car dealer was found discriminating against American Indian customers by charging them higher financing costs and fees.
On October 12, 2023, the CFPB and the DOJ issued a joint statement that reminds financial institutions that all credit applicants are protected from discrimination on the basis of their national origin, race, and other characteristics covered by the Equal Credit Opportunity Act, regardless of their immigration status. The joint statement was issued in light of consumers’ reports on being rejected for credit cards as well as for auto, student, personal, and equipment loans because of their immigration status, even when they have strong credit histories and ties to the United States and are otherwise qualified to receive the loans.
On September 19, 2023, the CFPB issued guidance about certain legal requirements that lenders must adhere to when using artificial intelligence and other complex models. The guidance describes how lenders must use specific and accurate reasons when taking adverse actions against consumers.
In this Compliance Clip (video), Adam gives an example of a disparate impact that actually that comes from the regulators. This example shows how an otherwise neutral policy or practice, applied equally to all credit applicants, can disproportionately exclude or burden certain persons on a prohibited basis.
On June 29, 2023, the CFPB released its Fair Lending Annual Report to Congress, describing its fair lending activities in enforcement and supervision; guidance and rulemaking; interagency coordination; and outreach and education for calendar year 2022. The Fair Lending Annual Report to Congress fulfills the Bureau’s statutory responsibility to report annually to Congress on public enforcement actions taken under the ECOA as well as the utility of the HMDA’s mortgage loan data collection requirements.
On April 19, 2023, the FHFA announced that it is seeking comment on a proposed rule that would formalize many of the Agency’s existing practices and programs regarding fair housing and fair lending oversight of its regulated entities. The rule would also expand requirements for the Enterprises in fair lending compliance and provide greater oversight and transparency regarding the Equitable Housing Finance Plans.
On November 14, 2022, Senior Deputy Comptroller for Bank Supervision Policy Grovetta N. Gardineer spoke at the 2022 CRA & Fair Lending Colloquium on behalf of the Acting Comptroller. Gardineer talked about several OCC priorities, including the OCC’s ongoing efforts to ensure that OCC regulated financial institutions provide fair and equitable financial services.
