CFPB’s ‘UDAAP’ Approach Is an Ambiguous Compliance Concern

Image: “Unfair and deceptive practices” have long been an enforcement area for consumer protection. Now the Consumer Financial Protection Bureau is adding an A for “abusive”—and taking away clarity for financial firms about what its UDAAP standard exactly means. “There is no list of clear black-and-white rules, and that’s what ...

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