American Bankers Association What is UDAAP 2013 National ...

American Bankers Association what is UDAAP . 2013 National and Why Should Conference for Community Bankers UCARE? Background February 14, 2013 - 2. Law and Regulation on UDAP. Section 5 of the FTC Act prohibits unfair or deceptive acts or practices in or affecting commerce.''. The prohibition applies to all persons engaged in commerce, including banks Regulation AA. Complaints Credit Practices Rule Unfair credit contract provisions Unfair or deceptive practices involving cosigners Unfair late charges February 14, 2013 - 3. Significant Guidance on UDAP. OCC Advisory Letter 2002-3. advisory-letters/2002 Federal Reserve Guidance for State Chartered Banks dated March 11, 2004. 2004/20040311 February 14, 2013 - 4. what is Unfair? Unfairness means the act or practice: causes or is likely to cause substantial injury to consumers which is not reasonably avoidable by consumers; and such substantial injury is not outweighed by countervailing benefits to consumers or to competition.

Section 1031 of Dodd-Frank The Bureau may take enforcement action to prevent —a covered person or service provider —from committing or engaging in an unfair, deceptive, or

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