Supervisory scrutiny of credit origination and servicing standards as well as consumer protection compliance has been growing since the 2008 global financial crisis and COVID-19 presents the next catalyst for change. The European Banking Authority published its final Guidelines on loan origination and monitoring May 29, 2020. On October 30, 2020 the EBA published a Compliance Table showing EU-27 Member States’, the ECB’s and the UK’s intention on how they plan to comply with the Guidelines, which will be implemented in three phases, i.e., June 2021, June 2022 and full operationalization by June 30, 2024. Given the breadth of impact, affected firms will likely need to work intensively, together with counsel, to prepare for compliance, including those steps as set out in this Client Alert.