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Updated UDAAP issue brief
NAFCU has updated the unfair, deceptive, or abusive acts or practices (UDAAP) issue brief. The update concerns a recent enforcement action, CFPB v. SettleIt Inc., in which a debt collection company was alleged to have engaged in abusive acts or practices by taking unreasonable advantage of the reasonable reliance by consumers on the company to act in the interest of the consumer.
NAFCU developed the issue brief to help credit unions understand the regulatory landscape and enforcement expectations under the bureau's authority.
In the issue brief, NAFCU provides background information on the creation of UDAAP under the Dodd-Frank Act and some context to the approaches utilized by the bureau and courts in evaluating alleged UDAAP violations.
The brief breaks down how the bureau determines whether an act or practice is unfair, deceptive, or abusive, citing previous bureau guidance, enforcement actions, and more. NAFCU also details patterns observed in the bureau's enforcement actions on the abusive prong to help credit unions avoid them.
Access the UDAAP issue brief here.
NAFCU will continue to highlight the importance of clear regulatory guidance and expectations as credit unions work to provide their members with safe, affordable financial products and services.