CFPB expands anti-discrimination focus

Consumer fairness is a vast concept that applies across the consumer lifecycle encompassing access and impact, sales practices, organizational disclosures, and ethical use of AI and machine learning. The CFPB’s announcement and updated examination manual for anti-discrimination and UDAAP helps “codify” this broader application of “fairness” for consumer financial products and services. Companies should note that CFPB is keenly focused on evaluating fairness across demographic groups; companies will be expected to show that they have conducted expanded and robust demographic analysis.