A Close Look At Recent UDAAP Actions: Part 1

Law360, New York (March 3, 2015, 12:07 PM EST) -- Consumer financial services companies have long been heavily regulated by a veritable alphabet soup of federal laws, including the ECOA, EFTA, FCRA, FDCPA, RESPA, SCRA and TILA. In the last few years, the industry has also increasingly faced the new darling tool of government enforcers — the prohibition of unfair or deceptive acts or practices (UDAP) found in Section 5 of the Federal Trade Commission Act[1] and the prohibition of unfair, deceptive, or abusive acts or practices (UDAAP) found in Section 1031 of the Dodd-Frank Act.[2]...

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