Financial Services Law Advisor
Legal Commentary and Resources for the Financial Services Industry
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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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 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.
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