FDIC potential referral to the DOJ
The FDIC alleged violations of the Fair Housing Act, based on a mid-sized state-chartered non-member bank’s allegedly low level of mortgage originations in certain communities. Based on these allegations, the FDIC also downgraded the institution’s CRA rating. Our attorneys advised the client, supervised preparation of responses to the FDIC’s allegations, and assisted in ongoing discussions with the FDIC. The FDIC ultimately decided not to pursue any formal enforcement action and reversed the CRA rating downgrade.