Our bank does not require closing protection letters (we don't sell loans on the secondary market) and in general we do not get closing protection letters. A new Loan Production Office that is working with new title service providers that are unfamiliar to the bank will start getting closing protection letters on all loans originated through that office only. Is that a fair lending or UDAP issue, requiring closing protection letters at 1 office, and not at any of the other offices?

Well, you either need them or you don't. Depending on the demographics of that office, then it is a potential. Talk to you legal counsel.

My involvement with these is minimal but I recall they were used as an enforcement tool during the blame game of mortgage losses during the last crisis. My question would be is this purely on the finance side or is there any fee for them passed to a borrower or applicant? (I'm not familiar with fees on them.) If there was a cost passed to the applicant, and the only branch doing this was in a minority area, and it was mostly or entirely those minorities paying the fees, I'd say there is a problem. If it is transparent to the applicant in the way they're treated and costs, I see little concern but you, management and counsel know your policies, products and vendors, I do not.