IBA Submits Comment Letter on Proposed Illinois CRA Rules. The IBA has submitted a comment letter to the IDFPR on our members’ concerns regarding the IDFPR’s proposed administrative rules implementing the Illinois Community Reinvestment Act (Illinois CRA). Our letter requests that the final rule adopt reasonable examination fees and limit expenses, lengthen the implementation period, ensure consistency with federal CRA rules and exam schedules, eliminate discrepancies with the proposed rules for credit unions and mortgage landers, and more. The IBA also contends that the proposal expands the IDFPR’s authority beyond the scope of the law by covering bank affiliates and foreign-headquartered banks. Read the IBA comment letter.
March 17, 2023
HUD Reinstates Disparate Impact Rule. The Department of Housing and Urban Development (HUD) has issued a final rule reinstating its 2013 rule establishing a framework for disparate impact litigation, following a U.S. District Court’s nationwide preliminary injunction against enforcing the later 2020 version of the rule. The final rule recodifies HUD’s original 2013 framework for determining liability based on a theory of disparate impact under the Fair Housing Act. The final rule is effective thirty days after publication in the Federal Register. View the announcement, final rule, and fact sheet.
March 20, 2023
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