Protecting against UDAAP violations

Implementing compliance training programs and carefully reviewing consumer complaints can help financial institutions guard against CFPB investigations

This article is the last in a four-part series on the Consumer Finance Protection Bureau (CFPB) and the broad powers with which it is armed to regulate financial institutions under the Dodd-Frank Wall Street Reform and Consumer Protection Act. Read parts one, two and three.  

In the first three articles in this series, we have outlined the origins of the CFPB, addressed its new definition of “abusive,” and discussed an institution’s exposure to liability for vendor actions in light of this new definition. In this article, we suggest ways in which financial institutions can protect themselves against unfair, deceptive or abusive acts and practices (UDAAP) violations through a combination of efforts, including employee compliance training, programs for receipt and analysis of consumer complaints, and increased consideration of financial products from the perspective of the lay consumer.

Contributing Author

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John Tumilty

John Tumilty is a member, and former Co-Chair, of Edwards Wildman Palmer's Commercial Litigation Practice Group. Based in Boston, he has handled numerous complex business disputes for...

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Contributing Author

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Raymond M. Ripple

Raymond M. Ripple is a partner in the litigation department of Edwards Wildman Palmer LLP in Providence, Rhode Island.


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