In a recent weblog post, the CFPB warned against creditors undertaking unfair and discriminatory servicing of debts during the COVID-19 crisis.  The CFPB explained:

We are monitoring the marketplace in real time and coordinating on an ongoing basis with fellow Federal and State regulators who are committed to stopping COVID-19-related malfeasance. We are taking, and will continue to take, swift action when we identify companies or individuals that violate the law to profit from the current economic uncertainty.While the Bureau is mindful of challenges faced by institutions, we will not hesitate to take public enforcement action when appropriate against companies or individuals that engage in unfair, deceptive, or abusive acts or practices, discriminate, or otherwise violate Federal consumer financial protection laws, in order to profit from the COVID-19 pandemic.  The CFPB also invited consumers to submit on-line complaints against creditors and debt collectors during this time, and set up a special hotline for industry whistleblowers and their current or former employees, contractors, vendors, and even competitor companies to report potential violations of Federal consumer financial law.

While the application of fair lending laws to loan servicing is not well-settled, enforcement actions for fair lending violations often have included prohibitions against discriminatory debt collection.  See, e.g. Hyman, S. J. & Kubota, E.S., Predatory Servicing, 72 Conf. Cons. Fin. L. Q. 43 (Summer 2018).