As the COVID-19 pandemic unfolds across the U.S. and around the world, it has created unprecedented challenges for financial institutions globally. These challenges have forced us to find new ways to execute our jobs and interact with our customers. The environment continues to quickly evolve — new issues, and ultimately opportunities, will arise over the coming weeks and months. We expect the regulatory climate will also change to address these new challenges as the federal and state governments provide stimulus packages and roll out new programs.
Our future outlook would suggest increased challenges/focus on areas such as:
Mortgage originations refinance process to ensure compliance with Regulation B.
The appraisal review process based on exterior-only, remote inspection, or accepting appraisal waivers.
Accuracy in the calculation of loss mitigation activities (fees, interest, etc.).
Ensuring fair debt collection practices that are not interpreted as taking advantage of the public panic situation.
Submission of accurate credit reporting activities to reflect regulatory guidelines.
Ensuring information privacy and protection while the majority of the workforce shifts to a remote model.
Ensuring existing business processes do not contain any Unfair, Deceptive, or Abusive Acts or Practices (UDAAP), especially in areas of marketing presentation, interest rate adjustment, etc.
Managing conflicting federal, state, and investor regulatory guidance.
Although these are only some examples of increased challenges in the consumer financial markets, we do estimate a reduction in volume of financial industry enforcement activities in the foreseeable future. Identifying new areas of increased risk and shifting focus to those areas will be a critical activity for financial institutions to maintain a fully compliant operation while facing the new challenges of 2020.