Discrimination and Bias in Residential Lending
The Importance of Assessment Areas
The FDIC, OCC, and U.S. Department of Justice (DOJ) have coordinated the release of new policies that will govern each agency’s consideration of bank merger transactions. The FDIC and OCC each published final statements of...more
On February 12, 2024, the Federal Financial Institutions Examination Council (FFIEC) issued a statement of principles that relate to valuation discrimination and bias for its member entities to consider in preparation for...more
A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more
The OCC, FDIC, NCUA and Fed have adopted a new Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts. The new policy statement updates, expands on and supersedes existing guidance from 2009,...more
June 29, 2023- Federal financial institution regulatory agencies today jointly issued a final policy statement on commercial real estate loan accommodations and workouts....more
March 30, 2023- The Consumer Financial Protection Bureau (CFPB) has finalized a rule required by Congress to increase transparency in small business lending, promote economic development, and combat unlawful discrimination....more
On February 22, the FDIC, Federal Reserve Board, and the OCC announced the publication of a joint notice and request for comment proposing changes to three versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051)...more
In light of growing concerns, the Federal Financial Institutions Examination Council (FFIEC) Appraisal Subcommittee (ASC) held its first hearing on appraisal bias on January 24, 2023, at the Consumer Financial Protection...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
The Federal Financial Institutions Examination Council (FFIEC), an interagency body of leading financial regulators, including the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency,...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more
We join the nation in mourning the passing of Supreme Court Justice Ruth Bader Ginsburg. Over her 20-year career before appointment to the D.C. circuit court, Justice Ginsburg fought for equal rights in the workplace, among...more
At the onset of the pandemic, many financial institutions offered credit accommodations, such as short-term deferrals and other loan modifications, to borrowers in response to the significant adverse impact caused by...more
Since early June 2020 when cries for racial justice resulted in a period of social unrest in the U.S., federal and state financial institution regulators have taken meaningful, proactive steps to acknowledge financial...more
In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more
On May 14, The Wall Street Journal ran a front-page article titled “Strapped Borrowers Inundate Lenders,” which discussed the efforts of banks to provide relief to consumer borrowers during the COVID-19 crisis. The article...more
Federal Reserve Revises Framework for Determining Control of a Banking Organization The Federal Reserve has adopted a final rule to simplify and clarify its regulations for determining control of a banking organization for...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) released a new guide to help financial technology companies and others partner with banks; the Financial Industry Regulatory Authority (FINRA) announced that it...more
The FDIC and OCC have issued new guidance for banks on heightened cybersecurity risks facing the financial services industry because of increased geopolitical tensions and threats of aggression. The guidance published on...more
Federal Banking Agencies Expand Eligibility to Use Streamlined Call Reports - The federal banking agencies have adopted a final rule to reduce regulatory reporting requirements for certain banks with total assets of less...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
The Federal Financial Institutions Examination Council (FFIEC) has issued a joint statement providing guidance for financial institutions about the role of cyber insurance in risk management of informational technology...more
On April 10, 2018, the Federal Financial Institutions Examination Council (the “FFIEC”), an interagency body composed of the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal...more
Editor's Note - Removal for Cause or Business as Usual? On April 5, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray testified before the House Financial Services Committee to give his semi-annual...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more