The Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) – together, the agencies – recently released proposed guidance on third-party risk management practices for banking organizations and credit unions. If finalized, the proposal would rescind and replace the 2023 Interagency Guidance on Third-Party Relationships: Risk …
California Law Strengthens Supervision of Mortgage Lenders for Fair Lending Compliance
California Gov. Gavin Newson recently signed the California Fair Lending Examination Act into law. The legislation requires the California Department of Financial Protection and Innovation (DFPI) to periodically examine banks, credit unions, and residential mortgage lenders and servicer licensees for compliance with fair lending laws. The act takes effect on January 1, 2027. The act is a recent example of states expanding their regulatory authority …
FinCEN, Other Regulators Clarify Use of Mobile Driver’s Licenses Under CIP Rule
On September 8, 2026, FinCEN, the Federal Deposit Insurance Corporation (FDIC), Federal Reserve, National Credit Union Administration (NCUA) and Office of the Comptroller of the Currency (OCC) jointly issued two new FAQs addressing how banks and credit unions may treat state-issued mobile driver’s licenses (mDLs) and other forms of government-issued digital credentials under the Customer Identification Program (CIP) Rule. The agencies also updated an existing …
FDIC, OCC Redefine ‘Unsafe or Unsound Practices’ and Raise Bar for MRAs
On September 1, 2026, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) published in the Federal Register a joint final rule that defines an “unsafe or unsound practice” under Section 8 of the Federal Deposit Insurance Act and modifies the agencies’ standards for issuing matters requiring attention (MRAs). The rule follows a notice of proposed rulemaking published …
Federal Agencies Rescind Interagency Statement on Special Purpose Credit Programs
Recently, the Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), Office of the Comptroller of the Currency (OCC), Consumer Financial Protection Bureau (CFPB), Department of Housing and Urban Development (HUD), Department of Justice (DOJ) and Federal Housing Finance Agency (FHFA) – together, the agencies – jointly rescinded the “Interagency Statement on Special Purpose Credit Programs Under the Equal Credit Opportunity Act and Regulation …
FTC Is Latest Federal Agency to End Disparate Impact Claims
On August 7, the Federal Trade Commission (FTC) announced in a policy statement that it will no longer pursue claims based on disparate impact or a theory of “unfair discrimination.” In the press release announcing the statement, the agency said it lacks the statutory authority to bring disparate impact claims under either the Equal Credit Opportunity Act (ECOA) or Section 5 of the FTC Act, …
NYDFS Issues Real-Time Alert on Software Exploitation
On August 11, 2026, the New York Department of Financial Services (NYDFS) issued an Industry Letter notifying its covered entities about an ongoing cybersecurity campaign targeting a known vulnerability in a monitoring and management software for managed service providers (MSPs) and IT departments. The vendor that provides the software published an update on August 10 informing its customers of the incident and providing further information …
OCC and FDIC Jointly Propose Changes to Community Reinvestment Act Regulations
On July 31, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) proposed amendments to their regulations implementing the Community Reinvestment Act (CRA), a Civil Rights-era anti-redlining law. The agencies’ proposal follows a winding regulatory and litigation history to amend CRA regulations. Most recently, the agencies issued final rules amending the CRA in 2023, which subsequently were …
Bank Regulators Push to Roll Back Anti-Redlining Standards
The Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) are expected to propose sweeping changes to the Community Reinvestment Act of 1977 (CRA) in the coming weeks – reportedly without the involvement of the Federal Reserve. While not formally confirmed, the OCC and FDIC are set to release a proposal that would raise the threshold for banks subject to …
Agencies Issue Guidance on Lending to Persons Not Authorized to Work in US
The Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC) and National Credit Union Administration (NCUA) recently jointly issued guidance reminding supervised financial institutions of their existing credit risk management obligations to borrowers who are not legally authorized to work in the United States (non-work-authorized borrowers). The guidance follows a recent White House executive order directing financial regulators to address risks “posed …