Summary of: HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard and Amendments to HUD’s Title VI Regulations
Updated 09/22/2026
The U.S. Department of Housing and Urban Development (HUD) is proposing two related changes to its disparate impact regulations. In January 2026 HUD issued a proposed rule that would remove HUD’s Fair Housing Act discriminatory-effects regulation at 24 CFR 100.500 and the related language in 24 CFR 100.5(b). In August 2026 HUD issued a supplemental proposal that would remove or revise several provisions in HUD’s Title VI regulations at 24 CFR 1.4 that HUD views as imposing liability for unintentional discriminatory effects. Together, the proposals would narrow HUD’s own regulatory use of disparate-impact standards and leave Fair Housing Act disparate-impact questions to the courts.
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