At its core, compliance is really about doing the right thing. But who gets to decide what’s right and wrong? The legislators who drafted the Dodd–Frank Wall Street Reform and Consumer Protection Act knew what they were doing when they wrote that lenders and financial service providers were prohibited from engaging in “unfair, deceptive, and […]
This week’s question addresses what the heck that second A in UDAAP stands for. Q: What does Abusive mean in UDAAP? Mike’s Answer: My initial reaction to that is that it’s a catch-all. If the CFPB doesn’t like what you’re doing, and it doesn’t really fit into the deceptive, or the unfair, abusive is it. […]
We get a lot of questions about UDAAP with the extra “A” so we thought we would revisit our post about it from the spring. Among the many acronyms, abbreviations, and jargon in the consumer finance industry, there are the obvious ones, and then there the assemblages of characters that look like the results of […]
We’ve said it before and we’ll say it again: to understand the CFPB, you need to understand another acronym—UDAAP. The Consumer Financial Protection Bureau exists, in large part, to guard consumers against what regulators deem “unfair, deceptive, or abusive acts and practices.” To that effect, half of the enforcement matters that the CFPB has made […]
There’s less than a week until our August webinar, Time for a Modern Compliance Program. On 8/23 at 11am Pacific (2pm Eastern), we’ll host an hour-long presentation about creating a compliance program flexible enough to survive today’s changing regulatory environment. Attendees will hear from a panel of industry veterans, including Michael Semanie, a business attorney […]
Innovation is in the eye of the beholder. The same tactics that automotive dealerships attempt to use to make more money from sales may appear, to regulators and attorneys, as unfair, deceptive, or abusive acts or practices.
At its core, compliance is really about doing the right thing. But who gets to decide what’s right and wrong? The legislators who drafted the Dodd–Frank Wall Street Reform and Consumer Protection Act knew what they were doing when they wrote that lenders and financial service providers were prohibited from engaging in “unfair, deceptive, and […]
Among the many acronyms, abbreviations, and jargon in the consumer finance industry, there are the obvious ones, and then there the assemblages of characters that look like the results of random pounding on a keyboard. “UDAAP” falls into the second category—but it’s not nearly as complicated as it looks. In theory, at least, UDAAP is […]
I was an “I can argue that” kind of kid in grade school. Oftentimes, when filling out a multiple choice test, I would actually write that line next to a question I thought was ambiguous. Of course, none of my teachers were ever impressed by this, nor did they ever jump at the chance to […]
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