National City Bank

On April 23, 2025, the President issued Executive Order 14281 on “Restoring Equality of Opportunity and Meritocracy,” which provides that “[i]t is the policy of the United States to eliminate the use of disparate-impact liability in all contexts to the maximum degree possible.” On April 22, 2026, the Bureau issued final amendments to the Equal Credit Opportunity Act’s (ECOA) implementing regulation, Regulation B, which state that ECOA does not authorize disparate-impact liability.