Staying Ahead of UDAP and Fair Lending Risk to Consumer Financial Services Providers Arising From the COVID-19 Pandemic

Summary: After looking at how the 2008 financial crisis and its aftermath might inform regulators’ response to the pandemic, we discuss how collections, loss mitigation/hardship programs, and originations of existing products and new programs designed to assist pandemic-impacted consumers (including changes to credit risk/fraud models to address the pandemic’s effects) can create UDAP and fair lending risk.