UDAAP
The Dodd-Frank Act added provisions allowing the Consumer Financial Protection Bureau (CFPB) to restrict “abusive” acts under their UDAAP authority. This is in addition to the Unfair and Deceptive Acts or Practices (UDAP) authority that existed under the FTC Act. These provisions under the Dodd-Frank Act could have the most impact on the operations of our member banks, both with regard to possible enforcement actions and upcoming rulemaking that would interpret these provisions. Examination guidelines issued by the CFPB also address UDAAP practices.
September 9, 2013
July 12, 2013Senate Rules Change Could Help Cordray be Confirmed Senate Majority Leader Harry Reid (D-NV) and Senate Minority Leader Mitch McConnell (R-KY) continued a heavy debate this week over the so-called “nuclear option.” Current Senate rules allow for Executive Branch nominees to be filibustered, forcing a 60 vote majority from the Senate for a confirmation. Traditionally, the Senate requires 67 votes...
June 28, 2013Supreme Court to Hear Recess Appointment Case On Monday, June 24, 2013, the Supreme Court agreed to hear a case that indirectly questions the validity of Richard Cordray as director of the CFPB. The case, Noel Canning v. NLRB , challenges the President’s recess appointment of several members of the National Labor Relations Board (NLRB). In January 2013, the US Court of Appeals for the District of...
February 22, 2013CFPB Consumer Advisory Board Meeting On Wednesday, February 20, 2013, the CFPB held a public meeting of the Consumer Advisory Board (CAB). The CAB is mandated by Section 1014 of the Dodd-Frank Act to advise and consult with the Bureau in the exercise of its function, and is required to meet at least twice a year. A list of the members can be found on the CFPB website . Though most of the business...Pages
Joint Trade letter to the CFPB on Auto Financing