The CFPB issued an interpretive rule. They did not have to follow notice and comment requirements because it is not a new requirement or regulatory change, it is an interpretation of an existing requirement.
If your bank has specific examples of what is covered in policies, procedures and especially in training materials, expanding those - especially training - would be advised but a boilerplate statement that "we comply with X," and X is a broad issue like "we do not consider sex in any phase of a loan process," then modifications are not required. Training staff that this is definitely a part of sex, that's all that's really needed.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell