Regulatory Alerts2025-08-29 | FIL-41-2025Update to the FDIC’s Consumer Compliance Examination Manual
The FDIC updated its Consumer Compliance Examination Manual to direct examiners in evaluating fair lending compliance under the Equal Credit Opportunity Act and Fair Housing Act. The guidance details prohibited discrimination factors, establishes three proof methods for lending discrimination (overt and comparative disparate treatment alongside disparate impact), and mandates risk-based examination scoping. Examiners must apply these flexible procedures to assess compliance management systems, select targeted focal points, and leverage statistical analyses or self-tests when verifying institutional adherence to fair lending obligations.
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