Links in “UDAAP”
- Recent Regulator Actions Added To UDAAP Database
PLA today updates the UDAAP Database with recent enforcement actions from prudential regulators, including the CFPB, FDIC, and the Board of Governors of the Federal Reserve System. A table illustrating these recent actions is viewable here. [1/6/16]
- How to Protect Yourself From Potential UDAAP Violations
Consumer complaints are a primary source used to trigger regulatory investigations for UDAAP and other regulatory violations. AffirmX Senior Vice President Jane Pannier provided guidance to a group of compliance officers and others on how to identify high risk complaints and steps credit unions can take to mitigate their risk. [11/9/15]
- FDIC Hits Comenity for UDAAP Violations
The FDIC hit Comenity Bank and Comenity Capital Bank $64 million in CMPs and restitution requirements for UDAAP related violations associated with deceptive practices in the Bank's marketing and servicing of credit card "add-on products." Comenity promotes co-branded credit cards through various retailers nationwide and cross promotes payment protection/debt cancellation add-on products to these cards. Key violations included practices on fees related to add-ons, material misrepresentations and omissions on product cancellations and gift cards. [9/11/15]
- Two Key Takeaways from CFPB’s Springstone Action
The CFPB's action against Springstone Financial for its deceptive credit enrollment practices in dental offices shows the the healthcare space is not outside the purview of the CFPB, as many have supposed. The second takeaway is that when staff makes representations that are inconsistent with the loan documents, UDAAP violations may follow. See also here. [8/21/15]
- Never Tell Me the Odds: UDAAP Strikes Back
Not so long ago, in a galaxy that is actually pretty close, attention to UDAAP heated up like a summer blockbuster. Here's a fun overview of UDAAP. [4/28/15]
- It’s a New Day for the CFPB: NewDay Financial LLC Pays Big
The CFPB has taken action against a Maryland-based nonbank lender, NewDay Financial, for deceptive advertising and kickback schemes. The company will pay $2 million in civil money penalties. [2/11/15]
- Deceptive Ads, Kickbacks Cost Maryland Lender $2M
Maryland-based lender NewDay Financial was hit for a $2 million penalty for deceiving consumers about a veteran's organization's endorsement and for a scheme to pay kickbacks for customer referrals. [2/11/15]
- FTC on a Debt-Collection Roll
FTC sent its annual letter to the CFPB on its efforts to combat deceptive, unfair or abusive debt-collection practices. In 2014, it filed 10 new cases, resolved nine more, obtained $140 million in judgments, and banned 47 companies and individuals. [2/10/15]
- Anti-Operation Choke Point Bill Reintroduced
The Financial Institution Customer Protection Act would forbid agencies from pressuring banks to cancel accounts unless there is a material reason. "This legislation needs to be codified into law so that other agencies don't ever fall into this illegal and abusive practice." [2/9/15]
- FTC: I’ll Call Your Debt Collection Threat and Raise You a Filed Complaint
The FTC didn't blink on illegal debt collection practices as it charged Texas-based Commercial Recovery Systems, Inc. of illegally threatening consumers with legal action and wage garnishment. The company also had their representatives falsely claim or imply that they were lawyers or judicial employees. [1/22/15]
