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OCC removes reference to disparate impact for examiners

July 16, 2025

On July 14, the OCC announced it has removed the references to disparate impact liability from the “Fair Lending” booklet of the Comptroller’s Handbook and has started removing references in other issuances. The OCC has also instructed examiners to no longer examine for disparate impact. Examiners form here on should not request, review, or conclude matters related to a bank’s disparate impact risk, internal disparate-impact risk analysis, or disparate-impact risk assessment processes or procedures.