The Consumer Financial Protection Bureau’s (CFPB) continued and expanded reliance on its sweeping authority to prohibit unfair, deceptive, and abusive acts or practices (UDAAP) continues to command the attention of financial institutions and financial services companies regulated by the agency and the number of CFPB UDAAP enforcement actions nearly doubled from 2013 to 2014.
To assist regulated and potentially regulated entities in understanding how the CFPB will exercise its UDAAP authority, we issued our “Know It When You See It” Client Alert in June 2014. That Alert included a chart listing the specific acts and practices that the CFPB had alleged and/or identified as unfair, deceptive, and/or abusive from its inception to May 2014. The CFPB has increased the pace of UDAAP enforcement activity significantly since then. Given the critical need to keep up with the CFPB’s ever-expanding interpretation of the scope of UDAAP, we have updated our previous “Know It When You See It” Alert through the end of 2014.
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