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Understanding Formal vs. Informal Rulemaking

There is a noticeable trend from federal financial institution agencies toward more informal rulemaking. Formal rulemakings are still in place, whether it be the Regulation B small business lending data collection rule, or the proposed Regulation Z r...
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HUD Strengthens the Effects Test

On March 17, 2023, the Department of Housing and Urban Development (HUD) issued a 184-page final rule reversing an early rule imposed in 2020, which limited the application of the effects test. The effects test refers to the principle that discri...
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NCUA Releases 2023 Supervisory Priorities

On Jan. 18, 2023, the National Credit Union Administration (NCUA) released its 2023 Supervisory Priorities. Compliance, of course, is once again one of their supervisory priorities, with the following focus areas mentioned: Flood Disaster Protection ...
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