UDAAP Archives - Page 2 of 5

July 15, 2024 by Bryce Noel in Collection Strategy

insideARM Weekly Recap – Week of July 8th, 2024

insideARM is here to help you keep up with the fast-paced ARM industry. This often requires keeping a finger on the pulse of the regulatory bodies, providing advice for more...

Drobot Dean / Adobestock

June 17, 2024 by Bryce Noel in CFPB

insideARM Weekly Recap – Week of June 10th, 2024

The debt collection industry is in a constant state of flux. The goal of the insideARM editorial team is to filter out the noise and pick the 3 pieces of...

Kenishirotide / Adobestock

June 11, 2024 by Kristen Larson in CFPB

CFPB Issues UDAAP Guidance On Contracts for Consumer Financial Products and Services

On June 4, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued a Consumer Financial Protection Circular 2024-03 (“Circular”) warning that the use of unlawful or unenforceable terms and conditions in...

THANANIT / Adobestock

March 27, 2024 by Kristen Larson in CFPB

CFPB Encourages New York to Ban Unfair or Abusive Conduct

On March 19, 2024, the Consumer Financial Protection Bureau (“CFPB”) published a blog touting letters it has sent to New York Governor Kathy Hochul, New York State Senate leaders, and...

Marco2811 / Adobestock

November 15, 2023 by John L. Culhane, Jr. in CFPB

CFPB Removes Changes Regarding Discrimination as an Unfair Practice From UDAAP Exam Manual but Appeals From District Court Order Vacating Changes

In September 2023, the CFPB updated its UDAAP Examination Manual to remove the changes it made in March 2022 which provided that unfair acts or practices encompassed discriminatory conduct, even...

sebra / adobestock

September 12, 2023 by Alan Kaplinsky in CFPB

Texas Federal District Court Invalidates CFPB Exam Manual Changes Which Opined that Discrimination is a UDAAP Violation

As we predicted long ago, on Friday, September 8, 2023, the Federal District Court for the Eastern District of Texas vacated the changes made in March 2022 to the CFPB’s...

Argus / Adobestock

August 10, 2023 by John L. Culhane, Jr. in Auto Finance Receivables

CFPB Sues Auto Loan Servicer for UDAAP Violations

Placeholder. The CFPB has filed a lawsuit in a Georgia federal district court against USASF Servicing (USASF) in which the CFPB alleges that USASF engaged in various unfair acts or practices in violation of the Consumer Financial Protection Act. USASF services retail installment sales contracts (RICs) originated by its affiliate, U.S. Auto Sales, Inc., which the CFPB describes as a “buy-here, pay-here car dealer.”

metamorworks / AdobeStock

July 13, 2023 by Missy Meggison in CFPB

CRC to CFPB: Abusive Act Policy Statement is Unclear; Will Harm Consumers

In April 2023, the CFPB released a policy statement on abusive acts and practices (Policy) and invited comments from interested stakeholders. According to the Consumer Relations Consortium (CRC), the ambiguity...

olly / AdobeStock

April 6, 2023 by Aryeh D. Derman in CFPB

Lowering the Bar: CFPB Unveils Its Playbook on Combatting “Abusiveness”

On April 3, 2023, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published a broad and wide-ranging Policy Statement on Abusiveness (“Policy Statement”) meant to assist “government enforcers” in identifying...

November 29, 2022 by Stefanie H Jackman in Auto Finance Receivables

CFPB Focuses on Junk Fees, Credit Reporting, and COVID-19 Relief Funds in Latest Supervisory Highlights

On November 16, 2023, the Consumer Financial Protection Bureau (CFPB) released a new Supervisory Highlights report, focusing on the auto servicing industry, consumer reporting, mortgage servicing, and COVID-19 relief funds....

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