Discrimination and Bias in Residential Lending
The Importance of Assessment Areas
What Happened? Building on the 2021 announcement of the Interagency Task Force on Property Appraisal and Valuation Equity (“PAVE”) and a series of federal agency actions in the intervening months, 2024 brings new efforts at...more
The Federal Financial Institutions Examination Council (“FFIEC”) published a statement on February 12, 2024 regarding “principles for the examination of supervised [institutions’] residential property appraisal and...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
On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more
The Federal Financial Institutions Examination Council’s Appraisal Subcommittee (ASC) will host a public hearing on appraisal bias on February 13, 2024. This will be the fourth public hearing on appraisal bias, and like the...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
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
On Dec. 15, 2022, the Federal Financial Institutions Examination Council’s (FFIEC) Task Force on Consumer Compliance adopted revised examination procedures for the Fair Debt Collection Practices Act (FDCPA) and its...more
In this Issue. The U.S. Securities and Exchange Commission’s (SEC) Division of Examinations recently published a risk alert spotlighting observations from its “RIC Initiatives”; the Federal Financial Institutions Examination...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
Senators Inquire about CFPB’s Fintech Agenda - On July 27, 2021, Senator Sherrod Brown, the Chairman of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to the Consumer Financial Protection...more
On August 11, the Federal Financial Institutions Examinations Council (FFIEC) issued new guidance, providing examples of effective authentication and access risk management principles and practices for financial institutions....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
On August 11, the Federal Financial Institutions Examination Council (FFIEC) issued guidance, titled “Authentication and Access to Financial Institution Services and Systems,” which provides financial institutions with...more
President Biden Issues an Executive Order on Competition with Implications for Financial Institutions - On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. The...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
Vendor management is a complex task, yet a necessary undertaking for any organization dealing with third parties. ...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
A black swan has arrived – the Pandemic of 2020 and with it a bear market. As with previous black swan events, experts and leaders are in learning mode, with the facts and events evolving hourly. As my financial advisor told...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