DWT Payments Team member Adam Maarec recently published the fourth article in a series that surveys activities identified as unfair, deceptive, or abusive (UDAAP) under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The latest survey covers activity between January 1, 2015 and June 30th, 2015, and identifies specific practices that allegedly violate the federal UDAAP prohibition.

The survey provides succinct summaries of UDAAP issues identified in:

  • 15 enforcement actions filed by the CFPB involving marketing, debt collection, debt settlement, and the servicing of mortgages, other loans, deposit accounts, and payment accounts.
  • 1 judicial opinion analyzing the merits of the CFPB’s allegations of abusive conduct against a for-profit college acting as a private student lender.
  • 2 CFPB Supervisory Highlights reports involving ACH payment cancellation terms, deposit account servicing, overdrafts, student loan servicing, “general waiver provisions” in home equity loan agreements, and mortgage servicing loss mitigation practices.