Financial Services Law Advisor
UDAAP Enforcement Action Database
We present below a database of enforcement actions that include allegations of unfair, deceptive, or abusive acts or practices (UDAAP) in connection with consumer financial products. The database focuses on enforcement actions by the Consumer Financial Protection Bureau, the Office of the Comptroller of the Currency, and the Federal Trade Commission. PLA intends the database to facilitate analysis of the themes and patterns in these agencies’ UDAAP enforcement actions. We will continue to update the database as new actions emerge.
The following resources may also be useful:
- CFPB Supervision and Examination Manual: UDAAP Section (as of October 2012)
- Federal Trade Commission Act Section 5: Unfair or Deceptive Acts or Practices
- Dodd-Frank Wall Street Reform and Consumer Protection Act Section 1031: Prohibiting unfair, deceptive, or abusive acts or practices
- Dodd-Frank Wall Street Reform and Consumer Protection Act Section 1036: Prohibited acts
We hope the database is useful and would welcome your feedback. Please contact us with your suggestions.
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Previous Speaking Engagements and Presentations
- ACI FinTech & Emerging Payment Systems Conference
April 30-May 1, 2019 | New York, NY
- American Banker Power of Prepaid
April 8-10, 2019 | Washington, D.C.
- Empire FinTech Conference
April 3, 2019 | New York, NY
- ACI Prepaid Card Compliance Conference
January 29-30, 2019 | Washington, D.C.
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Fearless in FinTech
December 3, 2018 | New York, NY
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Empire FinTech Conference
November 13, 2018 | San Francisco
- ABA Ninth Annual National Institute on Consumer Financial Services Basics
October 11-12, 2018 | Chicago, IL
- Artificial Intelligence and Machine Learning: IP Implications for Now and the Future
October 4, 2018 | Webinar
- ABA Business Law Section Annual Meeting 2018
September 13-15, 2018 | Austin, TX
- Startup Law 101: IP and Other Legal Foundations for Your Business
August 22, 2018 | Washington, D.C.
- National Bar Association 93rd Annual Convention & Exhibits
July 28 – August 3, 2018 | New Orleans, LA
- Opal Group – Financial Innovation and Payments Summit
July 18-20, 2018 | Newport, RI
- Financial Services Roundtable 2018 Spring Meeting of the Lawyers Council
May 17, 2018 | Washington, DC
- ACI’s FinTech & Emerging Payments Conference
May 1-2, 2018 | New York, NY
- Project W: Spring FemTech Meetup
April 19, 2018 | New York, NY
- Empire Startups – FinTech Conference
April 18, 2018 | New York, NY
- ABA Business Law Section Spring Meeting 2018
April 12-14, 2018 | Orlando, FL
- MCCA’s 2018 Global TEC Forum
April 12, 2018 | Austin, TX
- Power of Prepaid
April 9-11 2018 | Washington, DC
- CFPB: Working Towards Fundamental Reform
March 23, 2018 | Washington, DC
- NBLSA – 50th NBLSA National Convention
March 13-18, 2018 | New York, NY
- NBA – Commercial Law Section Annual Conference
February 15-17, 2018 | Dana Point, CA
- MMTC 9th Annual Social Justice Summit
February 6, 2018 | Washington, DC
- ACI’s 18th National Forum on Prepaid Card Compliance
January 29-31, 2018 | Washington, DC
- Financial Services Roundtable Consumer Working Group Meeting
January 18, 2018 | Washington, DC
- ABA – Consumer Financial Services Committee Meeting 2018
January 6-9, 2018 | Park City, UT
- FinTech Intel – Technology For Tomorrow’s Financial Institutions
December 13, 2017 | New York, NY
- Exploring the Data Aggregation Market: the CFPB’s Data Aggregation Principles and Their Potential Effect on the Delivery of Financial Services
November 29, 2017 | Webinar
- Empire Startups – FinTech Conference
November 14, 2017 | San Francisco, CA
- Financial Services Roundtable’s Lawyers Council meeting
November 6 2017 | Washington, DC
- 8th Annual National Institute on Consumer Financial Services Basics
October 2017 | Arlington, VA
- ABA – Business Law Section Annual Meeting 2017
September 14-16 | Chicago, IL
- Power of Prepaid
June 21-23, 2017 | Washington, DC
- NYPAY – Data Aggregation & Financial Services: Players and Issues
June 14, 2017 | New York, NY
- Wnet – Philadelphia Women Driving Payments Discussion
June 12, 2017 | Wilmington, DE
- Financial Services Roundtable – 2017 Lawyers Council Spring Meeting – “Regulation vs. Deregulation: Washington in Focus”
June 1-2, 2017 | Washington, DC
- ACI 3rd Annual Women Leaders in Financial Services Law and Compliance
May 22-23, 2017 | New York, NY
- Conference on Consumer Finance Law – 2017 Annual Consumer Financial Services Conference
May 15-16, 2017 | Chicago, IL
- Empire Startups – FinTech Conference
April 25, 2017 | New York, NY
- FemTech Leadership Meetup – Investing in Women: The Imperative, Challenge and Opportunity
April 26, 2017 | New York, NY
- CBA Live 2017 – Complaint Database: How to Manage Processes and Identify Enterprise Risk
April 3-5, 2017 | Dallas, TX
- ABA 2017 Business Law Section Spring Meeting
April 6-8, 2017 | New Orleans, LA
- NYPAY OCC FinTech Charter
February 21, 2017 | New York, NY
- NMLS 9th Annual Conference
February 13-16, 2017 | Austin, TX
- Consumer Financial Services Committee’s Monthly Call-In Program – Third-Party Access to Consumer Financial Information: Examining the Impact on Banks, Aggregators, and FinTech
February 15, 2017 | Washington, DC
- 8th Annual Broadband & Social Justice Summit – FinTech Empowerment Forum
February 7, 2017 | Washington, DC
- ACI’s 17th National Forum on Prepaid Card Compliance
January 30-31, 2017 | Washington, DC
- Alternative Lending Summit 2017
January 30-31, 2017 | Miami, FL
- Facilitating Collaborative Conversations: FinTechs & Banks – NYC Edition – FemTech Leaders Meetup
January 11, 2017 | New York, NY
- Strategic Venturing & Partnership Between FinTech & Financial Institutions Conference
January 25-26, 2017 | New York, NY
- Empire Startups FinTech Conference
November 7, 2016 | San Francisco, CA
- ABA Consumer Financial Services Basics Institute
October 17-19, 2016 | Arlington, VA
- ACI’s 16th Prepaid Card Compliance Conference
September 26-27, 2016 | Chicago, IL
- ACI’s 21st National Forum on Residential Mortgage Regulatory Enforcement and Litigation
September 26-27, 2016 | Dallas, TX
- ACI’s 13th National Forum on Emerging Payment Systems
September 15-16, 2016 | Washington, DC
- ABA Business Law Section Annual Meeting
September 8-10, 2016 | Boston, MA
- ABA Roundtable on MLA Rule
September 6, 2016 | Boston, MA
- Mobile Payments Conference 2016 – How Security of Mobile Payments Can Be Communicated to Encourage Adoption
August 30, 2016 | Chicago, IL
- ACI’s 12th National Forum on Emerging Payment Systems
July 28-29, 2016 | San Francisco, CA
- PayExpo Europe 2016
June 7-8, 2016 | London
- Regulating Prepaid: Balance Between Protecting Consumers & Promoting Payments
June 7, 2016 | New York, NY
- ACI’s 15th National Forum on Prepaid Card Compliance
June 2-3, 2016 | San Francisco, CA
- NYC FemTech Leaders Meetup
May 19, 2016 | New York, NY
- mCommerce: A Guide to Legal Issues in the Evolving Mobile Landscape
May 12, 2016 | Webinar
- NBPCA Power of Prepaid
April 28-29, 2016 | Washington, DC
- Empire Startups FinTech Conference
April 26, 2016 | New York, NY
- ACI Blockchain and Distributed Ledger Technology Conference
April 13-14, 2016 | New York, NY
- ABA 2016 Business Law Section Spring Meeting: Roundtable on the OCC’s Paper on Responsible Innovation
April 7, 2016 | Montreal
- Digital Payments Intensive 2016
April 13, 2016 | London
- FemTech Leaders Meetup
March 29, 2016 | New York, NY
- ACI 11th National Forum on Emerging Payment Systems
March 31-April 1, 2016 | Chicago, IL
- Nonprofits in the Digital Age SFO
March 24, 2016 | San Francisco, CA
- Commerce.Innovated. Presents: FinTech Regulations and What You Need to Know
March 21, 2016 | New York, NY
- NYC Inaugural FemTechLeaders Meet Up
January 20, 2016 | New York, NY
- Nonprofits in the Digital Age NYC
March 9, 2016 | New York, NY
- ACI Prepaid Card Compliance
January 28-29, 2016 | Washington, DC
- What APIs Enable
February 8, 2016 | New York, NY
- ABA 2016 Consumer Financial Services Committee Meeting
January 9-12, 2016 | Park City, UT
- ACI Cross-Border Global Payments and Technologies
November 19-20, 2015 | New York, NY
- CCFL’s Annual Consumer Financial Services Conference
November 19-20, 2015 | Chicago, IL
- Empire FinTech Startups Conference
November 10, 2015 | San Francisco, CA
- ACI’s Consumer Lending Regulatory Compliance Conference
October 29-30, 2015 | New York, NY
- ACI’s 13th National Forum on Prepaid Card Compliance
September 30-October 1, 2015 | Chicago, IL
- Evolution of the Mobile Payment Market (A New York Technology Council Event)
October 15, 2015 | New York, NY
- ACI’s 10th Emerging Payment Systems Conference
September 17-18, 2015 | Washington, DC
- ABA’s Committee on Consumer Financial Services
September 18, 2015 | Chicago, IL
- ACI’s 3rd National Forum on Crypto, Virtual and Digital Currency and Payment Systems
June 24-25, 2015 | Chicago, IL
- Milken Institute’s Center for Financial Markets: Innovation and Regulation
June 25, 2015 | Washington, DC
- NBPCA’s Power of Prepaid
June 11-12, 2015 | Washington, DC
- Financial Services Roundtable Consumer Working Group
May 29, 2015 | Washington, DC
- FinTech Startups Conference
April 7, 2015 | New York
- Digital Payments Intensive
April 16, 2015 | London
- ACI’s 9th Emerging Payment Systems Conference
March 26-27, 2015 | Chicago, IL
- Re-Identification Risks for Credit Card Data
March 10, 2015 | Webinar
- The CFPB’s Prepaid Proposal: Reg E, Reg Z, and Overdrafts
February 19, 2015 | Webinar
- ACI’s 11th National Prepaid Card Compliance Forum
January 29-30, 2015 | Washington, DC
- LSI’s Conference on Technology Law
December 8-9, 2014 | Seattle, WA
- ACI’s 2nd National Forum on Virtual & Digital Currency and Payment Systems
November 20-21, 2014 | New York, NY
- Money2020
November 2-6, 2014 | Las Vegas, NV
- Operation Chokepoint And The Brave New World Of Criminal Liability
October 30, 2014 | Seattle, WA
- ACI’s 10th National Forum on Prepaid Card Compliance
October 6-7, 2014 | Chicago, IL
- ACI’s 8th Emerging Payment Systems Conference
September 22-23, 2014 | Washington, DC
- ABA Business Law Section Annual Meeting
September 11-13, 2014 | Chicago, IL
- New York Technology Council: Social Commerce
September 11, 2014 | New York, NY
- Virtual and Digital Currency and Payment Systems
June 24-25, 2014 | Chicago, IL
- BIT’s 3rd Annual World Congress of Emerging InfoTech 2014
June 19-21, 2014 | Dalian, China
- NBPCA’s Power of Prepaid
June 11-13, 2014 | Washington, DC
- Payments eXchange 7th Annual Prepaid, Payments & Mobile Retreat
May 28-29, 2014 | Toronto, ON
- ABA Regulatory Compliance Conference
June 8-11, 2014 | New Orleans, LA
- InsideCounsel 14th Annual SuperConference
May 10-12, 2014 | Chicago, IL
- The Cloud and Big Data 2014
April 22-23, 2014 | Seattle, WA
- ABA Business Law Section Spring Meeting
April 10-12, 2014 | Los Angeles, CA
- Crypto Currencies: Bitcoin and Beyond
April 8, 2014 | Seattle, WA
- ACI’s 7th National Forum on Emerging Payment Systems
March 24-25, 2014 | San Francisco, CA
- NBPCA Government Affairs Working Group Telebriefing: Intersection of Virtual Currency and Prepaid
March 13, 2014 | Telebriefing
- All Payments Expo: Fraud and Cybercrime Panel
March 4, 2014 | Las Vegas, NV
- You Say You Want a Revolution? Virtual Currency Issues & Opportunities for FIs (NACHA Webinar)
February 19, 2014 | Webinar
- ACI’s 9th National Forum on Prepaid Card Compliance
January 30-31, 2014 | Washington, DC
- NBPCA Prepaid Card Workshop for Regulators, Policy Makers, Law Enforcement, and Industry
January 29, 2014 | Arlington, VA
- LSI’s Conference on Information Technology Law
December 12-13, 2013 | Seattle, WA
- LSI’s The Second Annual Conference on Mobile Payments Law
November 21-22, 2013 | Palo Alto, CA
- RAMP Advanced Commerce and Mobile Retail Services Summit
October 28-30, 2013 | Chicago, IL
- Money2020
October 6-10, 2013 | Las Vegas, NV
- ACI’s 8th National Forum on Prepaid Card Compliance
October 3-4, 2013 | San Francisco, CA
- Addleshaw Goddard International Financial Services Convention
September 26-27, 2013 | London
- ACI’s 6th National Forum on Emerging Payment Systems
September 18-19, 2013 | Washington, DC
- Law Seminars International Mobile Payments
September 9-10, 2013 | Washington, DC
- American Bar Association Annual Meeting
August 8-13, 2013 | San Francisco, CA
- Mobile Commerce World 2013
June 24-26, 2013 | San Francisco, CA
- ACI’s 2nd Annual Forum on International and Cross-Border Payments
June 13-14, 2013 | San Francisco, CA
- Merchant Strategies for Mobile Payments
May 13-14, 2013 | Seattle, WA
- Electronic Transactions Association (ETA) Compliance Day
April 30, 2013 | New Orleans, LA
- Cloud Services and Related Big Data Issues
April 29-30, 2013 | Seattle, WA
- Social Media: What You Need to Know to Meet New Regulatory Expectations
April 23, 2013 | Webinar
- RAMP Advanced Commerce and Mobile Retail Services Summit
April 15-17, 2013 | Chicago, IL
- ACI’s 5th National Forum on Emerging Payments
March 21-22, 2013 | San Francisco, CA
- ACI’s 7th Annual Forum on Prepaid Card Compliance
January 29-30, 2013 | Washington, DC
- Law Seminars International Technology Law Seminar
December 13, 2012 | Seattle, WA
- ACI Forum on International and Cross-Border Payments
November 27-28, 2012 | New York, NY
- FACTA and the Dodd-Frank Act: What You Must Know
November 27, 2012 | Webinar
- Law Seminars International Mobile Payments Conference
November 15-16, 2012 | San Francisco, CA
- Mobile Payments: Regulatory and Security-Related Challenges
November 1, 2012 | Bloomberg BNA Webinar
- Law Seminars International Wireless Broadband Seminar
November 5-6, 2012 | Seattle, WA
- ACI’s 6th Prepaid Card Compliance Program, West Coast Edition
October 11-12, 2012 | San Francisco, CA
- RAMP: Advanced Commerce & Mobile Retail Services Summit
October 1-3, 2012 | Chicago, IL
- ACI’s 4th National Practical, Legal, and Compliance Forum on Balancing Innovation with Consumer Protection in Emerging Payment Systems
September 27-28, 2012 | Washington, DC
- American Legislative Exchange Council 39th Annual Meeting
July 25-28, 2012 | Salt Lake City, UT
- ABA Regulatory Compliance Conference
June 11, 2012 | Orlando, FL
- Law Seminars International’s Conference on Mobile Payment Systems: New Business Models and Associated Legal Issues
May 17, 2012 | Atlanta, GA
- International CTIA WIRELESS
May 8-10, 2012 | New Orleans, LA
- 26th Annual Payment Card Institute
May 3, 2012 | Arlington, VA
- Mobile Monday Washington — Mobile Commerce
April, 23, 2012 | Washington, DC
- American Conference Institute’s Conference on Emerging Payment Systems, West Coast Edition
April, 16, 2012 | San Francisco, CA
- RAMP Advanced Commerce & Mobile Retail Services Summit
April 2-4, 2012 | Chicago, IL
- Fair Credit Reporting Act (FCRA): Nuts and Bolts (American Bankers Association Telephone Briefing)
March 14, 2012 | Telephone Briefing
- FFIEC Authentication Guidance Examination in 2012: Are You Prepared?
March 8, 2012 | Webinar
- American Conference Institute’s 5th Annual Forum on Prepaid Card Compliance
January 30, 2012 | Washington, DC
- Payments — Innovations and Old Plumbing
December 1, 2011 | London, UK
- Law Seminars International’s Third Annual Advanced Conference on Wireless Broadband Developments
November 15, 2011 | Seattle, WA
- Monetizing Digital Media: Current Opportunities and Challenges (Presented by Davis Wright Tremaine and Rutberg and Company)
October 27, 2011 | New York, NY
Previous Events DWT Payments Team Members Attended
- Startupbootcamp Amsterdam – FinTech & CyberSecurity FastTrack Event
June 22, 2018 | New York, NY
- Startupbootcamp Amsterdam – New York CyberSecurity Meetup
June 21, 2018 | New York, NY
- Tearsheet Forum: Bank of the Future
June 21, 2018 | New York, NY
- FSR – Moving Past the Great Recession in the Trump Era: A New Direction for Consumer Financial Services
February 20-21, 2018 | Washington, DC
- FemTech MeetUp – The Incubator/Accelerator Experience: How to get selected and how to make the most of the experience
February 27, 2018 | New York, NY
- NMLS 10th Annual Conference
February 6-9, 2018 | New Orleans, LA
- ABA – Financial Crimes Enforcement Conference
December 3-5, 2017 | National Harbor, MD
- Consult Hyperion/NYPAY 6th Annual Tomorrow’s Transactions New York Unconference
September 11, 2017 | New York, NY
- Trade Development Alliance – Complying with U.S. Export Controls 2017
June 8-9, 2017 | Seattle, WA
- Startup Bootcamp FinTech San Francisco Meetup
April 13, 2017 | San Francisco, CA
- TAG 2017 FinTech GA
February 9, 2017 | Atlanta, GA
- ABA Consumer Financial Services Committee Winter Meeting
January 12-15, 2017 | Carlsbad, CA
- NYPAY – Blockchain, Tokens, Chips: How Best to Fight Fraud?
November 17, 2016 | New York, NY
- FinTech Series: Crowdfunding & Peer-to-Peer Payments
October 26, 2016 | Washington, DC
- NYPAY – What’s Next for the Networks in a World of Faster Payments?
October 18, 2016 | New York, NY
- MTRA 2016 Annual Conference
September 19-22, 2016 | Tucson, AZ
- NYPAY Next Money Entrepreneurship
September 7, 2016 | New York, NY
- FSR Consumer Working Group In-person Meeting
August 11, 2016 | Washington, DC
- Consensus 2016
May 2-4, 2016 | New York
- EMV 8 Months Later- Was That Really What We Expected?
May 3, 2016 | New York, NY
- FSR 2016 Lawyers Council Spring Meeting
May 5-6, 2016 | Washington, DC
- Women in Housing & Finance 2016 Annual Symposium – Transformation in Financial Services: The Impact of Financial Technology (FinTech)
April 14, 2016 | Washington, DC
- ABA 2016 Spring Consumer Financial Services Committee Meeting
April 6-9, 2016 | Montreal
- Will the Blockchain Eliminate the Need for Payment Intermediaries? (NYPAY)
April 13, 2016 | New York
- Money Transmitter Regulators Association (MTRA) Annual Conference
October 5-8, 2015 | Kansas City, MO
- IPSA International Summer Social
August 25, 2015 | New York, NY
- NYC FinTech Extravaganza
September 15, 2015 | New York, NY
- ETA / PCI Technology of Payment Security Policy Day
September 16, 2015 | Washington, DC
- ABA 2015 Business Law Section Annual Meeting
September 17-19, 2015 | Chicago, IL
- BITS Emerging Payments Forum
June 2-3, 2015 | Washington, DC
- ABA 2015 Business Law Section Spring Meeting
April 14-16, 2015 | San Francisco, CA
- ABA 2015 Consumer Financial Services Committee Meeting
January 10-14, 2015 | New Orleans, LA
- MTRA 2014 Annual Conference
November 5-6, 2014 | Boston, MA
- ABA Consumer Financial Services Committee 2014 Winter Meeting
January 10, 2014 | Park City, UT
- NBPCA Prepaid Insider
December 3, 2013 | New York, NY
- ABA Business Law Section Spring Meeting
April 4-6, 2013 | Washington, DC
- NACHA Council MEGA Meeting 2012
October 3-4, 2012 | Atlanta, GA
- Consumer Financial Protection Regulations: How Do They Measure Up?
September 13-14, 2012 | Philadelphia, PA
- FTC Workshop on Mobile Payments and Their Impact on Consumers
April 26, 2012 | Washington, DC
- NACHA Internet Council Winter Meeting: Digital Wallets: Holy Grail of Payments Convergence?
February 29-March 1, 2012 | Tampa, FL
- ABA Consumer Financial Services Committee 2012 Winter Meeting
January 7-10, 2012 | Park City, UT
- ABA Business Law Section Banking Law 2011 Fall Committee Meeting
November 3-5, 2011 | Washington, DC
- NACHA Council MEGA Meeting 2011
October 19-20, 2011 | Boston, MA
The financial services industry continues to undergo dynamic change along many dimensions—for example, the macroeconomic environment, product design and value propositions, technology, the identity and number of market participants, corporate and portfolio transactions, the role of the networks, legislation and regulations, enforcement priorities, and even the underlying regulatory paradigm. Still, many processes, requirements and other features of the industry remain relatively unchanged.
The DWT banking and financial services team addresses these changes and continuities every day, leveraging our presence on both coasts and our many years of industry experience in payments; FinTech; and bank and consumer financial regulation, enforcement, investigations and litigation. With Financial Services Law Advisor, we offer commentary on new developments that seem particularly significant, as well as resources that we believe can be helpful to others who are tasked with anticipating, understanding and addressing these developments.
We welcome your comments, questions, and—especially—your suggestions.
Meet the Banking and Financial Services Team
