This joint resolution invokes chapter 8 of title 5 (the Congressional Review Act) to disapprove the Office of the Comptroller of the Currency's rule titled “Quality Control Standards for Automated Valuation Models” (89 Fed. Reg. 64538 (Aug. 7, 2024)).
The single-paragraph text states that the named rule "shall have no force or effect."
That outcome is consequential beyond striking a regulation from the Federal Register. Disapproval under the CRA not only nullifies the rule but also triggers a statutory bar on issuing a replacement in "substantially the same" form without new legislative authorization.
For banks, mortgage originators, appraisal providers, and investors that rely on automated valuation models, the resolution would remove a federal, uniform set of minimum quality-control expectations and shift regulatory oversight back toward supervisory practice and other authorities.
At a Glance
What It Does
The resolution uses the Congressional Review Act to revoke the OCC rule on quality-control standards for automated valuation models and declares that the rule has no force or effect. By invoking chapter 8 of title 5, it also invokes the CRA's downstream restriction on reissuing a substantially similar rule without explicit congressional authorization.
Who It Affects
National banks and federal savings associations regulated by the OCC are the primary subjects; secondary impacts reach mortgage lenders that rely on AVMs, fintech providers of valuation models, appraisal management companies, and investors in mortgage-related assets who depend on valuation consistency.
Why It Matters
This is an unusual use of the CRA in the financial-regulatory space because it targets model-governance standards rather than a pricing or disclosure rule. Nullifying the rule changes the compliance baseline for model risk and could leave a regulatory gap that supervisors, other agencies, or market participants must fill.
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What This Bill Actually Does
The joint resolution is short and mechanically simple: it identifies the OCC rule on "Quality Control Standards for Automated Valuation Models" by Federal Register citation and declares that rule null and void. Because the resolution is framed under chapter 8 of title 5, it is a Congressional Review Act disapproval, not a substantive amendment to bank law.
The operative legal effect flows from the CRA rather than from language in the resolution itself.
Under the CRA, a successful disapproval resolution does two things: it strips the specified rule of legal effect, and it bars the issuing agency from promulgating a replacement rule in "substantially the same" form unless Congress authorizes it. Practically, that means the OCC would lose a formal, published set of minimum quality-control standards for AVMs; the agency could still use supervisory examinations, nonbinding guidance, or enforcement actions under existing statutes, but it could not readopt substantially the same text as a rule without fresh statutory authority.For compliance teams, the immediate consequence of enactment would be the removal of a clear regulatory baseline that many banks were preparing to incorporate into model governance frameworks.
That creates short-term uncertainty around what standards examiners will apply and longer-term ambiguity about whether the market will converge on voluntary norms, interagency guidance, or state-level requirements. The resolution does not itself replace the rule with an alternative standard — it acts as a statutory veto that redirects the policy conversation to supervisors, other regulators, or Congress.
The Five Things You Need to Know
The resolution names the OCC rule by Federal Register citation: 89 Fed. Reg. 64538 (August 7, 2024).
It declares that the specified OCC rule "shall have no force or effect," removing the rule from the body of binding federal regulations.
Because it invokes chapter 8 of title 5 (the Congressional Review Act), the disapproval also triggers the CRA’s prohibition on issuing a replacement in "substantially the same" form without new congressional authorization.
The targeted rule established minimum quality-control standards for automated valuation models—standards that would have set clear compliance expectations for national banks using AVMs in mortgage and lending processes.
The resolution does not create a substitute regulatory framework; it nullifies the OCC's rule and leaves enforcement, examiners’ expectations, and market practices to evolve without that federal regulatory floor.
Section-by-Section Breakdown
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Identification of the rule and statutory vehicle
The resolution opens by citing the title—disapproval under chapter 8 of title 5—and identifies the OCC rule by name and Federal Register citation. That placement matters because invoking chapter 8 signals that the resolution seeks the special CRA remedy rather than proposing a different regulatory text or amendment to bank statutes.
Single operative sentence nullifying the rule
The core text consists of one operative sentence: Congress disapproves the rule and it "shall have no force or effect." Legally, that is the disposition: the rule is erased from the body of binding regulations. The clause does not articulate remedial measures, transitional mechanics, or savings provisions for actions taken under the rule prior to its nullification.
Consequences carried by the CRA beyond nullification
Although the resolution's text is short, invoking chapter 8 attaches statutory consequences embedded in the CRA—most notably the bar on reissuing a "substantially the same" rule and the potential for expedited congressional review of future rulemaking. Those consequences arise by reference to the CRA and are not restated in the resolution; implementation questions (for example, what counts as "substantially the same") would be resolved under existing statutory interpretation and case law.
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Explore Finance in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- National banks and federal savings associations: They gain regulatory relief from a prescriptive, uniform set of AVM quality-control requirements, reducing near-term compliance costs and paperwork tied to implementing the published standards.
- Fintech AVM providers: Firms that build or supply automated valuation models avoid a new, binding federal minimum standard that could have imposed development, documentation, and validation obligations.
- Mortgage originators and servicers: Lenders relying on AVMs get temporary operational certainty that the OCC’s specific rule obligations will not be imposed as binding federal regulations.
Who Bears the Cost
- Borrowers and consumers: Removing a federal floor for AVM quality controls may increase the risk of inaccurate valuations, which can affect loan pricing, underwriting outcomes, and the fairness of transactions involving property.
- Appraisal professionals and valuation firms advocating for stricter standards: They lose a mechanism that would have required certain controls, potentially exposing the market to uneven quality and increased competition from less-regulated AVM usage.
- OCC and other regulators: The OCC loses a rulemaking tool and faces the harder task of maintaining model-risk oversight through examinations and guidance; other agencies and market participants may also face coordination costs if standards diverge.
Key Issues
The Core Tension
The central dilemma is between reducing prescriptive regulatory burdens on banks and vendors—fostering operational flexibility and innovation—and providing a clear, uniform regulatory floor to manage model risk and protect borrowers; nullifying the rule solves one problem (regulatory burden) while reintroducing uncertainty and potential safety risks that the rule aimed to address.
The resolution is legally simple but politically and operationally complex. The CRA’s bar on reissuing a "substantially the same" rule is intentionally broad and fact-sensitive; regulators and courts have struggled with what counts as "substantially the same," so the OCC could face uncertainty about what forms of supervisory guidance, interpretive rules, or narrowly tailored regulations would cross the statutory line.
That ambiguity can chill agency action or lead to novel, narrowly focused rulemaking strategies that avoid the appearance of repetition.
Nullification also produces an implementation gap: banks that had started to align model-validation programs, documentation, or vendor contracts to the OCC’s standards may have to decide whether to continue with those investments, revert to prior practices, or adopt private standards. Market participants may respond by developing industry-led standards or by seeking interagency guidance; either path risks fragmentation and uneven consumer protections across charter types and states.
Finally, the resolution does not close the door on supervisory enforcement under existing law—exams and enforcement actions can still target unsafe model practices—but those remedies are less transparent and offer less legal predictability than a published rule.
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