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 …
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, …
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 …
CFPB Rescinds Advisory Opinion on Special Purpose Credit Programs
On June 17, the Consumer Financial Protection Bureau (CFPB) rescinded its 2020 advisory opinion “Equal Credit Opportunity (Regulation B); Special Purpose Credit Program,” which addressed regulatory uncertainty regarding the application of the Equal Credit Opportunity Act’s Regulation B to certain aspects of special purpose credit programs (SPCPs) “designed by for-profit organizations to meet special social needs.” The advisory opinion had clarified the content a for-profit …
Spotlight on CFPB’s Recent Statement on Ability to Pay and Immigration Status
The Consumer Financial Protection Bureau (CFPB) issued a statement reminding creditors that assessing a consumer’s ability to pay debt obligations under the Truth in Lending Act (TILA) may warrant or require consideration of immigration status when relying on an individual’s employment income. The statement follows a recent White House executive order designed to mitigate risks to the financial system “posed by the extension of credit …