Insights
Client Alert
The New UDAAP: The CFPB "Abusive Standard" Will You Know It When You See It?
June 27, 2013
BY THE GLOBAL BANKING AND PAYMENT SYSTEMS PRACTICE
The Stay Current highlights the CFPB’s recent settlement involving the agency’s first enforcement action to curtail so-called “abusive” practices with respect to the offer and sale of consumer financial products and services. The introduction of the “abusive” standard is a new development in the arena of consumer financial protection and, until now, the CFPB had offered limited insight as to the types of practices that could be deemed to be abusive. The client alert discusses this recent development and the highlights of the recent CFPB settlement relative to the future of consumer financial protection enforcement.