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Jake Fowler

Fairness Issues in Default Servicing and Debt Collection: Lessons Learned from Recent Consent Orders



  • Lynn Woosley, Engagement Director, Treliant LLC
  • Brenda Baylor, Director, Treliant LLC
  • Rodd Lynch, Senior Manager, Treliant LLC


With little fanfare, regulators have released several loan servicing and debt collection consent orders in the past 18 months. This webinar will cover principles of fair debt servicing, key take-aways from the consent orders, and possible monitoring and test strategies to manage your institution’s risk.


  1. Principles of fair servicing
  2. Lessons learned from recent consent orders
  3. Monitoring and testing to manage your risk


  1. Review of fair servicing principles and practices
  2. Summary of servicing and collection practices resulting in consent orders
  3. Suggestions for ongoing monitoring and testing in each line of defense

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Lynn Woosley, CRCM

Engagement Director, Treliant, LLC

Lynn Woosley is an Engagement Director with Treliant, LLC.  She is a seasoned executive with extensive risk management experience in regulatory compliance, consumer and commercial credit risk, credit and compliance risk modeling, model governance, regulatory change management, acquisition due diligence, and operational risk in both financial services and regulatory environments. 

Over the last two decades, Lynn has held leadership positions including Senior Vice President and Fair and Responsible Banking Officer; Group Vice President for Wholesale Transaction Modeling; and First Vice President for Portfolio Management within the Enterprise Risk Management division of a top 10 bank.  Prior to joining the private sector, Lynn served as Senior Examiner and Economist at the Federal Reserve Bank of Atlanta.   
With strong knowledge and experience across multiple risk disciplines, Lynn has been a featured speaker for numerous banking, compliance, and CRA conferences across the country. Lynn has authored several articles and presentations on financial institution risk management and consumer protection issues.  She has also developed training materials related to fair lending, fair housing, UDAAP, credit risk management, credit scoring, and consumer protection topics. 
Lynn holds a BBA and an MBA from Middle Tennessee State University and an MS Finance from Georgia State University.  She is a Certified Regulatory Compliance Manager and a Commissioned Examiner of the Federal Reserve System. Lynn has also served as both Chair and Vice-Chair of the Consumer Bankers Association’s Fair and Responsible Banking Committee. 

Brenda Baylors

Director, Treliant LLC

Brenda Baylor, a Director with Treliant, is a Certified Regulatory Compliance Manager (CRCM) with 22 years of experience in regulatory compliance, risk management, and banking. Her specialties include fair lending laws and regulations; the Community Reinvestment Act (CRA); Home Mortgage Disclosure Act (HMDA); and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP). Brenda advises clients on the implementation of regulatory compliance programs, risk assessments, monitoring, and statistical analytics programs, as well as examination readiness and risk management strategies. 

Prior to joining Treliant, Brenda worked in the capacities of CRA Officer and Compliance Officer at large regional banks. In these roles, she led efforts related to program development, monitoring, analysis, policy writing, executive-level reporting, training, examination management, and regulatory reporting. Additionally, as a former Senior Consultant at Ernst & Young, she specialized in complex fair lending analytics and data integrity reviews for national banks. Brenda also acquired in-depth knowledge of enterprise risk management programs for large financial institutions through her employment at KeyBank, where she functioned in the capacities of Risk Consultant and Consumer Compliance & Quality Control Manager. 
Brenda’s recent contributions to industry publications include: 

      -“Are Foreign Language Communications Risky Business?” in the Fall/Winter issue of Treliant’s New Coordinates

      -“Walking a Tightrope,” an article on fair lending analytics technology in The MReport (November 2016);

      -“Redlining Risk: Slaying the Three-Headed Dragon,” in Mortgage Banking Magazine (October 2016); and 

      -Content updates to the 2015 Reference Guide to Regulatory Compliance, the American Bankers Association’s official study guide to the CRCM examination. 

Brenda graduated summa cum laude with a BA in Accounting from Marietta College.  

Rodd Lynch

Senior Manager, Treliant LLC

Rodd Lynch, a Senior Manager with Treliant, is an experienced regulatory executive with 27 years in the financial services industry. Rodd has an extensive background addressing a broad range of compliance and risk management requirements, including fair lending (Regulation B, Fair Housing Act), the Community Reinvestment Act (CRA), the Home Mortgage Disclosure Act (HMDA), Unfair, Deceptive, or Abusive Acts or Practices (UDAAP), and the Servicemembers Civil Relief Act (SCRA). He is an energetic leader with proven strategic vision and the ability to facilitate changes that improve clients’ services, strengthen regulatory compliance, and increase operating efficiencies and internal controls.  

Rodd has held senior compliance leadership positions in several organizations, and has experience in providing advice and counsel to institutions of all sizes and structures. Most recently, he was the Senior Vice President and Director of Fair and Responsible Banking/CRA at Customers Bank, where he developed and grew the compliance framework guiding the institution from $3 billion to over $10 billion in assets and fully prepared the bank for supervision by the Consumer Financial Protection Bureau (CFPB). Rodd has held similar positions with First Niagara Bank, TD Bank, and Sovereign Bank (now Banco Santander). In these roles, he interacted with all levels of management at regulatory agencies including the Office of the Comptroller of the Currency (OCC), Federal Reserve Bank of Philadelphia (FRB), Office of Thrift Supervision (OTS), Department of Justice (DOJ), and CFPB. His accomplishments include: 

     -Developed and implemented fair and responsible banking programs in three separate financial institutions, ranging in asset size from $3 billion to $270 billion; 

     -Created an online consumer complaint management system that met CFPB expectations; and

     -Led multiple organizations to achieve satisfactory or outstanding ratings on compliance exams conducted by the aforementioned regulators. 

Rodd holds a BA from Temple University. He is a Green Belt in Six Sigma Process Improvement.  

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