In December, the Consumer Financial Protection Bureau (CFPB) participated in the annual Fair Lending Interagency Webinar, along with numerous other government enforcement agencies. During this webinar, the CFPB focused much of its time on appraisal bias and the emphasis placed on addressing discrimination in valuations, including under its Unfair, Deceptive or Abusive Acts or Practices (UDAAP) authority. The CFPB did not, however, provide any insight or guidance related to its recent expansion of UDAAP to expressly include discrimination as an “unfair” practice to both credit and non-credit products.
This webinar discussion and other recent pronouncements indicate a continuation of the increased enforcement activity the CFPB has undertaken over the last two years, utilizing various laws in increasingly broader applications. This increased enforcement approach has wide-ranging implications, impacting numerous types of credit and other financial services offerings.
Join Husch Blackwell’s Consumer Financial Services team for a discussion of the enforcement methods and approach being used by the CFPB, and strategies to stay in compliance and reduce your exposure.
Topics
- How courts and regulators are applying ECOA to the credit process overall, including the CFPB’s position on the extension of ECOA to the life cycle of a loan
- The CFPB’s expansion of UDAAP to include discrimination in non-credit products
- The Interagency Fair Lending Exam Procedures, including regulators’ procedures to detect disparate treatment and disparate impact through statistical analysis, and the challenges of this for non-mortgage products
- A preview of the upcoming Section 1071 rule covering small business lending data collection and the compilation, maintenance, and submission to the CFPB of certain data on applications for credit for women-owned, minority-owned, and small businesses
Presenters
Maureen Clark, Attorney
Marci Kawski, Partner
Lisa Lawless, Attorney
Leslie Sowers, Partner
Who Should Attend
General counsel, mortgage lenders, small business lenders, compliance officers and risk officers of licensed lenders, auto finance companies, banks, and credit unions
Continuing Education Credit
This program is pending approval for Colorado, Illinois, Iowa, Kansas, Missouri, Nebraska, Tennessee, Texas and Wisconsin continuing legal education credit.
Did you miss the webinar?
The webinar recording is available after the event date. Simply register using this on-demand link to access the recorded program.