By Keith Bradley, Katie Wechsler and Dimitar Georgiev-Remmel (March 24, 2022, 5:48 p.m. EDT) — On March 16, the Consumer Financial Protection Bureau released revised review guidelines on unfair, deceptive acts and practices or abusive, or UDAAP.
The changes explain a new position of the CFPB: discrimination in the provision of financial products and services to consumers can be a UDAAP. We anticipate that potentially discriminatory practices in all aspects of these markets will come under increased scrutiny from the bureau and other regulators.
The bureau’s new UDAAP concept marks a significant shift, and all providers of financial products and services – outside of lending, where the Equal Credit Opportunity Act has long been in effect – can…
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