The National Credit Union Administration has removed all references to disparate impact liability from its Fair Lending Guide and other issuances and will no longer incorporate disparate impact reviews into its examination and supervision processes, aligning its approach with White House Executive Order 14281. Supervisory activity will no longer include requests for, review of, conclusions about, or follow-up on a credit union’s disparate impact risk, internal disparate-impact risk analysis, or disparate-impact risk assessment processes and procedures. The agency will continue to conduct fair lending examinations and risk assessments and will take appropriate action where it finds evidence of disparate treatment or other violations, consistent with applicable law.
National Credit Union Administration 2025-09-04
National Credit Union Administration removes disparate impact references from its Fair Lending Guide and ends disparate impact reviews in supervision
The National Credit Union Administration has removed references to disparate impact liability from its Fair Lending Guide and will no longer conduct disparate impact reviews, aligning with White House Executive Order 14281. Supervisory activities will exclude disparate impact risk assessments, though fair lending examinations will continue, with actions taken for disparate treatment or other violations.