Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Update
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Understand the scope of UDAAP authority and learn practical solutions you can take to reduce the risk of becoming the CFPB's next enforcement target.Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) continues to be a primary area of focus for regulators. Violations range from several different product types along with varying types of violations. This material will provide an overview of UDAAP along with the genesis of the rule, provide specific examples of types of UDAAP violations, restitution amounts over time, along with the outlook of UDAAP. You should leave with a strong background on the rule and how regulators have used this rule to cite different violations and enforcement actions.
Authors
Michael Canale, BRG Vincent Urbancic, CFA, BRGAgenda
Overview of UDAAP
• Meaning
• What Makes a Violation UDAAP
Examples of UDAAP Violations
• Types of Violations
• Historical Counts
• Processes Associated With UDAAP
Restitution Associated With UDAAP
• Types of Restitution
• Historical Restitution
• Combination of Violations With UDAAP
Future Outlook
• What Historical Trends Predict Future of Violations
• What Have Regulators Indicated Will Be Areas of Focus