Survey of UDAAP Activities Under the Dodd-Frank Act

DWT Payments Team member Adam Maarec recently published the third article in a series that surveys activities identified as unfair, deceptive, or abusive (UDAAP) under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The latest survey covers activity between July 1, 2014, and December 31, 2014, and identifies specific practices that allegedly violate the federal UDAAP prohibition.

The survey provides succinct summaries of UDAAP issues identified in:

• 20 enforcement actions issued by the CFPB, including 3 joint actions with state attorneys general, that involve banks, installment lenders, retailers, student loan servicers, and telecommunication providers, among others;
•  1 state regulatory enforcement action;
• The CFPB’s most recent Supervisory Highlights report that address sales of credit card debt and student loan servicing; and
• CFPB guidance on the marketing of credit card promotion APR offers and certain practices under the Credit Practices Rules.

Click here to read the latest survey. You can also find the source documents for each action in our UDAAP Enforcement Action Database.

Adam discussed this survey while moderating a roundtable titled “UDAAP Issues Throughout the Credit Lifecycle” at the American Bar Association Consumer Financial Services Committee’s winter meeting this weekend.