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Recent Fair Appraisal Developments
In the past month, there have been a number of new fair appraisal-related developments, each of which are summarized below. First, the United States Department of Justice (DOJ) announced that it had filed a Fair Housing Act suit against Rocket Mortgage, citing allegations of appraisal discrimination following an earlier complaint from HUD.
Proposed Settlement Order Requires Marriott to Provide Request to Delete Rights
On October 9, 2024, the Federal Trade Commission (FTC) announced a proposed settlement order (the “Proposed Order”) with Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC (collectively referred to as “Marriott”). The Proposed Order addresses allegations that Marriott failed to implement reasonable security procedures and practices in connection with three separate data breaches.
OCC Issues Bulletin with Guidance on Refinance Risk
On October 3, 2024, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2024-29, which provides banks with guidance on managing credit risk associated with refinance risk (the “Bulletin”). The Bulletin addresses the impact of refinance risk on credit risk in commercial loan transactions and portfolios.
OCC’s Supervisory Operating Plan for 2025
On October 1, 2024, the Office of the Comptroller of the Currency (OCC) released its bank supervision operating plan, outlining the agency’s supervision priorities and objectives for the 2025 fiscal year (“OCC 2025 Operating Plan”).
Table of Contents
CONSUMER FINANCE
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Recent Fair Appraisal Developments
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Statement Released on Citadel Federal Credit Union’s Redlining Settlement
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Agencies Release 2025 Thresholds for Certain Consumer Lending Rules
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Federal Regulators Increase Number of Penalties Assessed in First Half of 2024
BANKING OPERATIONS & FINTECH
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Proposed Settlement Order Requires Marriott to Provide Request to Delete Rights
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California Enacts New Overdraft and NSF Fee Legislation
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CFPB Publishes Final Rule Establishing Regulatory Framework for Open Banking
COMMERCIAL LENDING
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OCC Issues Bulletin with Guidance on Refinance Risk
CORPORATE GOVERNANCE
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OCC’s Supervisory Operating Plan for 2025
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California Legislature Extends Deadlines for State Board to Issue Climate Disclosure Regulations
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California Delays Compliance Dates for Digital Financial Asset Law
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