The Consumer Financial Protection Bureau (CFPB) recently released its Semi-Annual Report to Congress covering its activities from January to June 2026. The report describes the CFPB’s continued emphasis on deregulation, violations involving measurable consumer harm, voluntary remediation, and a shift away from reliance on novel legal theories and duplicative federal and state oversight. It highlights the CFPB’s significantly pared-down enforcement and supervisory activities while noting …
OCC Releases Yearlong Debanking Review, CFPB Opens Parallel Investigation
The Office of the Comptroller of the Currency (OCC) released findings from a yearlong review of nine of the largest national banks it supervises by asset size, covering the period from 2020 through September 2025. The review followed the Trump administration’s August 2025 Executive Order 14331, “Guaranteeing Fair Banking for All Americans,” which directed federal banking regulators to examine whether banks had engaged in unlawful debanking …
CFPB Highlights Major Changes to Fair Lending Approach in Annual Report
The Consumer Financial Protection Bureau (CFPB) recently released its annual fair lending report, covering its fair lending activities in calendar year 2025, as well as certain 2026 actions it considered particularly relevant and important. The report reflects changes to the CFPB’s fair lending program, many in response to Trump administration executive orders, to streamline its fair lending activities by focusing on “proven, intentional racial discrimination …
State AG Coalition Issues Multistate Guidance on Antidiscrimination Protections
A coalition of 14 state attorneys general recently issued joint guidance on antidiscrimination protections “to clarify the state of the law” for their residents and “reaffirm [their] commitment to defend and enforce civil rights laws.” The coalition included the attorneys general of California, Delaware, Hawaii, Illinois, Maryland, Massachusetts, Michigan, Minnesota, Nevada, New Mexico, New York, Oregon, Vermont and Washington. The guidance indicates that state and …
DOJ Fraud Division Announces New Corporate Enforcement Priorities
On October 1, 2026, Assistant Attorney General Colin M. McDonald, head of the Department of Justice’s new National Fraud Enforcement Division, issued Directive 26-12, titled “Corporate Enforcement in the Fight Against Fraud” (memorandum). The memorandum expands on the Division’s initial set of priorities set forth in an August 13, 2026 memorandum, rearticulate these priorities, and set criteria for new and ongoing investigations against companies, while …
Federal Agencies Propose New Guidance for Third-Party Risk Management
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
On September 30, 2026, California Gov. Gavin Newson 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 …
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 …
HUD Joins National Fraud Detection Center
On August 25, 2026, the Department of Housing and Urban Development Office of Inspector General (HUD OIG), announced a partnership with the Department of Justice (DOJ) through the launch of the National Fraud Detection Center (NFDC). The NFDC is a prosecutor-led, multi-agency effort intended to strengthen coordination among federal law enforcement, offices of inspector general and state partners in detecting and dismantling fraud schemes targeting …
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, …