Fair Lending and UDAAP Considerations During the COVID-19 Era

As financial institutions scramble to accommodate their deposit and loan customers while also funding new rounds of Paycheck Protection Program loan applications, they should ensure that fair lending risks and unfair or deceptive practices are quickly identified and addressed. The Great Recession of 2008 serves as a reminder that federal and state regulators will be on the look-out for violations of fair lending and UDAP/UDAAP laws. Their heightened vigilance could result in adverse examination reports, supervisory issues, and enforcement actions. Please join us for a discussion that will include the following topics:

• Lessons learned from the Great Recession and the likelihood of enforcement actions in the COVID-19 aftermath
• Overview of fair lending and UDAP/UDAAP risks in consumer and small business lending
• Key operational areas for fair lending and UDAP/UDAAP risks including: marketing and advertising, customer service and call centers, collections, and loss mitigation
• Special considerations for mortgage lending and servicing (refinance boom and loss mitigation/foreclosure)
• Practical advice on risk mitigation