UDAP vs. UDAAP

Answered by:

Question:

Where does the CFPB’s authority come in when they determine something is “Abusive”?

Answer:

The Dodd-Frank Act empowered the CFPB to enforce UDAP type issues and added the extra “A” for “Abusive.” The original source for UDAP, Section 5 of the Federal Trade Commission Act, continues to exist and the other agencies have already said Section 5 violations can still be cited.