CFPB Examination Manual v.2 (OSee ct. 2012) at UDAAP 1 (CFPB Exam Manual). To the extent that this Bulletin cites FTC guidance or authority, such references reflect the views of the FTC, and are not binding upon How to "Adaapt" to UDAAP 2 Wolters Kluwer Financial Services Looking Back - CFPB Publishes UDAAP Guidance When the CFPB published their UDAAP examination guidelines and procedures, they laid out definitions of the terms Unfair, Deceptive and Abusive with examples to help illustrate these terms as seen in the table below. BNA INSIGHTS: The CFPB and Data Security Enforcement. one of the booklets that comprise the FFIEC Information Technology Examination Handbook The CFPB's UDAAP authority applies only to covered persons (and their service providers) to the extent they offer a "consumer financial product The CFPB & UDAAP: A "Know It When You See It" Standard? Subscribe; The CFPB & UDAAP: A "Know It When You See It" Standard? trying to understand how the CFPB will exercise its UDAAP authority based on the allegations in enforcement actions and CFPB statements in its Examination Manual and The CFPB examination manual's UDAAP (unfair, deceptive, or abusive acts or practices) section addresses the importance of the consumer complaint process. UDAAP violations can cause significant financial injury to consumers, erode consumer confidence, and undermine the financial marketplace. Bottom line - everyone wants to avoid UDAAP issues! The Elaborate Guessing Game: The CFPB and Its Authority Under the UDAAP a financial institution can attempt to understand the exercise of the CFPB's authority under UDAAP based upon the allegations in enforcement actions and the statements contained in the CFPB's Examination Manual and See CFPB Exam Manual at UDAAP 5] Third, what is an abusive act or practice? This is more nuanced than the foregoing elements, but there are two primary factors: (1) the act or practice materially interferes with the ability of a consu