The Abusive Standard “Extra A,” in UDAAP

The Abusive Standard “Extra A,” in UDAAP

CFPB has published a policy statement on the Abusive standard “Extra A,” in UDAAP. Consumer Compliance professionals who’ve been practicing their art since 2010 likely remember the day that “extra A” helped UDAAP become famous. That “extra A” was for the new Abusive...
Reviewing for Potential UDAAP Issues

Reviewing for Potential UDAAP Issues

Reviewing For Potential Unfair, Deceptive, Abusive Acts and Practices (UDAAP) Issues: On March 8, 2023, the CFPB issued a special edition of their Supervisory Highlights publication to highlight issues noted at financial institutions and servicers regarding junk fees....