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Regulatory: Keeping the bureau at bay

Effectively managing the risks of UDAAP under Title X of the Dodd-Frank Act is essential.

This column is part of a series of articles on the new Consumer Financial Protection Bureau and the upcoming wave of regulations affecting the consumer financial industry.

For banks and other financial services companies, the Dodd-Frank Act’s prohibitions against unfair, deceptive, or abusive acts or practices (UDAAP) are suddenly a top compliance risk. Consumer financial products and services must now meet amorphous and, let’s face it, subjective standards that can easily be used by regulators and others to meet statutory and regulatory gaps, and to achieve policy goals, some of which may not yet be revealed.   

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Martin Bishop

Martin J. Bishop is a partner, litigation department vice chairman and co-chair of the consumer financial services litigation practice at Foley & Lardner LLP. He...

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