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ABA, State Associations: HUD’s Disparate Impact Rule Ignores Supreme Court Precedent (8/21/18) In promulgating its 2013 rule implementing the Fair Housing Act's discriminatory effects standard, the Department of Housing and Urban Development erred in ignoring Supreme Court precedent on determining disparate impact, ABA and 52 state bankers associations wrote in a comment letter to HUD. ABA and the state bankers associations called on HUD to amend the rule to include a proper definition of a disparate impact claim; articulate the cautionary standards, safeguards, limitations and other requirements described by the Supreme Court in its Inclusive Communities decision; and provide further guidance to the industry. For more information, contact ABA's Rod Alba​.

OCC Updates CRA Policies and Procedures Manual (8/17/18) The OCC updated its policies and procedures manual to clarify its policy and methodology for determining how evidence of discrimination or illegal credit practices will affect a bank’s Community Reinvestment Act rating. The updated version replaces a previous edition of the manual issued in October 2017. ABA created a side-by-side comparison of the manuals . ABA members must login to view the comparison chart. For more information, contact ABA's Krista Shonk​.


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See the Bureau's series of Requests for Information (RFIs) seeking comment on its enforcement, supervisory, rulemaking, market monitoring, and educational activities.

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