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If the bank owns OREO properties, does the bank need to abide by the fair lending laws with regard to these properties?
Institutions need to have controls in place to ensure compliance with fair lending laws including fair housing laws. The institution must also consider the Fair Housing Act when marketing and selling the property.
Reference: Federal Reserve Board's Q&As for Federal Reserve Regulated Institutions Related to Management of OREO, June 28, 2012 - Q22 & Q29.