UDAAP
The Dodd-Frank Act added provisions allowing the Consumer Financial Protection Bureau (CFPB) to restrict “abusive” acts under their UDAAP authority. This is in addition to the Unfair and Deceptive Acts or Practices (UDAP) authority that existed under the FTC Act. These provisions under the Dodd-Frank Act could have the most impact on the operations of our member banks, both with regard to possible enforcement actions and upcoming rulemaking that would interpret these provisions. Examination guidelines issued by the CFPB also address UDAAP practices.
- February 22, 2013CFPB Consumer Advisory Board Meeting On Wednesday, February 20, 2013, the CFPB held a public meeting of the Consumer Advisory Board (CAB). The CAB is mandated by Section 1014 of the Dodd-Frank Act to advise and consult with the Bureau in the exercise of its function, and is required to meet at least twice a year. A list of the members can be found on the CFPB website . Though most of the business...