Expanded Use of Dodd-Frank UDAAP Provisions: Enforcement and Examination by CFPB and State AGs, Recent Federal and State Cases, State Authority under § 1042, Officer and Manager Liability as a “Related Person,” and More
Sanjay Ibrahim
Partner
Parker Ibrahim & Berg LLC
Andrew K. Stutzman
Stradley Ronon Stevens & Young LLP
- UDAAP enforcement actions
- How to deal with the overlap in State and Federal jurisdiction
- State AG’s and the CFPB
- The CFPB’s focus on UDAAP
- What practices has the CFPB targeted?
- States’ authority under § 1042
- Recent case law
- Assessing the definition of ‘abusive’ practices
- Potential pitfalls for financial institutions
- What types of products or aspects of origination and servicing may be ‘abusive’?
- Lessons learned from recent enforcement actions
- Addressing potential UDAAP concerns
- Minimizing exposure to UDAAP issues