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ARTICLE · 13 NOVEMBER 2023

Consumer Financial Services: UDAAP Round-Up

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Welcome to the latest edition of the UDAAP Round-Up. This newsletter is designed to provide you with a periodic resource to stay abreast of federal activities regarding the prohibition on unfair...

United StatesFinance and Banking

Letter to Readers

Welcome to the latest edition of the UDAAP Round-Up. This newsletter is designed to provide you with a periodic resource to stay abreast of federal activities regarding the prohibition on unfair, deceptive, or abusive acts or practices ("UDAAPs") in the consumer financial services space. In this edition, we cover notable policy, enforcement, and supervisory developments from April through September 2023.

During this period, we saw 18 UDAAP/UDAP complaints and consent orders from the Consumer Financial Protection Bureau ("CFPB" or the "Bureau"), the Federal Trade Commission ("FTC" or "Commission"), and the Office of the Comptroller of the Currency ("OCC"),1 numerous UDAAP supervisory findings from the CFPB, and UDAP/UDAAP-related guidance from the CFPB, FTC, and OCC.

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