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Welcome to Compliance 911, a no-nonsense, cut to the point, style show for today’s busy bank and credit union compliance professionals. With this series of bi-weekly shows our goal is to boil down some of today’s hottest regulatory compliance topics in quick and easy to digest 5-10 minute episodes so you can get the information you want and get on with your day. We’ll be discussing topics like CRA, HMDA, Fair Lending, Anti Money Laundering, and so much more. Don’t forget to subscribe and tell a friend about us! Follow M&M Consulting and GeoDataVision us on LinkedIn to get the latest updates.
Episodes
Sep 4, 2025
Sep 4, 2025
22 min
Hosts Dean Stockford and Len Suzio welcome Lori Sommerfield, a partner at Troutman Pepper Locke LLP, to discuss and explain President Trump’s Executive Order 14281 (April 23, 2025), which directs federal agencies to limit use of the disparate impact theory in fair lending enforcement and to review existing guidance, pending matters, and consent orders that leverage that theory.
The federal banking agencies are removing disparate impact references in their examination manuals and shifting toward intentional discrimination theories, while use of the disparate impact theory by state authorities and private litigants remain risks. Banks and financial services companies should continue to review policies and procedures for potential disparate impact, conduct rigorous fair lending monitoring and testing, and prepare for potential future shifts in enforcement.
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