UDAAP: Unfair, Deceptive, or Abusive Acts or Practices

UDAAP is not a single statute. It is a supervisory and enforcement standard assembled from Dodd-Frank sections 1031 and 1036, which give the CFPB authority over unfair, deceptive or abusive acts or practices in consumer finance, and FTC Act section 5, which the FTC and the prudential banking agencies enforce. Because no codified list of prohibited conduct exists, exposure is assessed case by case against three legal tests, which is why UDAAP appears in almost every US consumer-facing compliance role.

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