There’s a new “A” in UDAAP.

The CFPB enforcement action has released new regulations for fillings under UDAAP. Adam Maarec, Laurie Lucas (associate professor of legal studies and William S. Spears Chair in Business Administration at Oklahoma State University), and John Morton (Member in Gordon Feinblatt’s Financial Services Practice Group) wrote a survey that “reviews the Bureau of Consumer Financial Protection’s (CFPB’s) enforcement actions involving allegations of abusive conduct taken under the authority of the Consumer Financial Protection Act of 20101 (CFPA), which, among other things, prohibits unfair, deceptive, and abusive acts or practices (UDAAP).”

Under the CFPA, if an

"act or practice . . . materially interferes with the ability of a consumer to understand a term or condition of a consumer financial product or service,” the CFPB has the authority “to declare [that] act or practice [to be] abusive.”