CFPB Pushes Equity Envelope Via Updated UDAAP Examination Manual

While credit-related products have long been subject to the anti-discrimination requirements of the Equal Credit Opportunity Act (ECOA), providers of non-credit financial products, such as payments, credit reporting services, deposit accounts, remittance transfers, and debt collectors and buyers, should take note of the CFPB's announcement (the Announcement) that it will examine all entities and financial products subject to its jurisdiction for possible discriminatory behavior. The CFPB has likewise updated its examination manual on potentially unfair, deceptive or abusive acts and practices (UDAAPs) to expressly require examinations to evaluate potentially discriminatory conduct during UDAAP examinations.