Links in “UDAAP”

Sometimes the "if you think you have a UDAAP problem, you do" sniff test doesn't quite cut it; CFPB releases bulletin giving potential examples of unfair, deceptive and/or abusive acts or practices. [8/14]

Compliance officer surmises that if the latest remittance rules were a bank advertisement, the CFPB would have to cite it as a UDAAP violation. [8/13]

UDAAP related type judgment against online operation for $9.5 million. Good template review of practices provided in complaint. [7/31]

Using the actual/360 interest accrual method on a $100 million portfolio earnings can increase earnings for a financial institution by over a $1 million, but will it attract regulatory attention as an Unfair, Deceptive or Abusive Act or Practice? [7/29]

CFPB expresses "significant concern" with potentially deceptive claims made in communications with consumers concerning the effect of paying debts in collection on credit reports, credit scores, and creditworthiness. [7/25]

While the number of mortgage loan originators who were actually involved in deceptive and abusive practices was very small, all MLOs and their institutions must now follow the SAFE Act requirements; what this means in a nutshell. [7/23]

Partial settlement against EFTA and UDAAP violations on payday lender with additional ruling that affiliated American Indian Tribe entities remain under coverage of TILA, FTC Act (UDAAP) and EFTA. [7/22]

Powerful connection to UDAAP makes this must-reading for all direct and indirect Debt Collectors and related Departments/Functions.

Related: FTC issues largest Debt Collection Penalty of $3.2 million. See http://www.ftc.gov/opa/2013/07/nco.shtm [7/10]

Critical lessons for all auto lenders to avoid enforcement penalties, supervisory citations and regulatory enforcement. Important lessons. Expands key UDAAP-Type Principles. [6/28]

Interesting angle on deception in advertising. Application to FIs merits consideration. [6/25]