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ARTICLE · 30 MARCH 2022

CFPB Updates UDAAP Exam Manual To Target Discrimination

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On March 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced changes to its supervisory operations for the stated purpose of positioning the CFPB to better protect families and ...

United StatesFinance and Banking
Richard Alexander
Richard Alexander
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Robert Azarow
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David Freeman, Jr.
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Amber A. Hay
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Michael Mancusi
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Kevin Toomey
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Christopher Allen
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On March 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced changes to its supervisory operations for the stated purpose of positioning the CFPB to better protect families and communities from illegal discrimination, including in situations where fair lending laws may not apply. These changes are reflected in the CPFB's Supervision and Examination Manual (the Manual) under its procedures for evaluating unfair, deceptive or abusive acts or practices (UDAAPs). The Manual now explicitly incorporates anti-discrimination considerations in determining UDAAPs and directs examiners to consider evidence of discrimination when identifying potential UDAAPs and determining whether UDAAPs have occurred.

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