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CFPB order includes UDAAP compliance outline
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Banking
Friday, September 16, 2016
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Although the Consumer Financial Protection Bureau (CFPB) has for some time scrutinized violations of the Dodd-Frank Act’s prohibition on Unfair, Deceptive or Abusive Acts or Practices (UDAAP), a recent bureau consent order has taken the extra step of requiring a respondent to establish a UDAAP risk-management program.
The CFPB ordered First National Bank to “develop a written, enterprise-wide UDAAP risk-management program for any consumer financial products or services” it offers, potentially signaling its growing interest in pursuing UDAAP violations, in a recent consent order against the bank.
According to one compliance expert, all financial service companies under the CFPB’s oversight would be wise to follow the consent order's model. Read on for details of what the CFPB expects.
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