UDAAP Exposure: How Can Banks Manage the Increased Risk?


California banks’ exposure to Unfair, Deceptive and Abusive Acts and Practices (UDAAP) is increasing. The CFPB has revoked its prior guidance limiting UDAAP exposure, indicating a likely intent to enforce UDAAP issues aggressively. The California Department of Financial Protection and Innovation’s UDAAP authority over FinTechs and debt collectors increases banks’ risk when they utilize the services of such companies. Explore these increased risks, and the need for ever stronger vendor management, compliance, training and other risk management oversight.

Michael Flynn
Of Counsel