US EditionOCC Removes Disparate Impact Provisions from Exam Manual - Weiner Brodsky Kider PC
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OCC Removes Disparate Impact Provisions from Exam Manual - Weiner Brodsky Kider PC
The Office of the Comptroller of the Currency (OCC) issued a bulletin and revised a fair lending examination manual to remove references to disparate impact liability. The President issued an executive order in April 2025 stating that agencies must eliminate the use of disparate impact liability to the fullest extent allowed by law and must deprioritize enforcement activity based on disparate impact (see prior coverage here). The OCC has now re…
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