DWT payments team member Adam Maarec recently co-authored an article entitled "A Survey of Activities Identified as Unfair, Deceptive, or Abusive by the CFPB," published by the American Bar Association.
In January 2014, the authors released a survey of activities identified as unfair, deceptive or abusive (UDAAP) by the CFPB in 2012 & 2013. The new article updates the previous survey with additional enforcement actions brought by the CFPB between January 1, 2014 and June 30, 2014. It has also been expanded to cover enforcement actions by state attorneys general and consumer financial services regulators using federal UDAAP powers created by the Dodd-Frank Act.1 The CFPB and state attorneys general and consumer financial services regulators often coordinate their enforcement activities, so these actions – like actions initiated directly by the CFPB – also provide insight into the specific types of practices that could be considered UDAAP violations.
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