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"Post-crisis AG enforcement is just the beginning" by Michelle L. Rogers (Law360)


Michelle L. Rogers

UDAAP — the prohibition against unfair, deceptive, or abusive acts or practices — is now ubiquitous in government enforcement actions, due in large part to the Consumer Financial Protection Bureau’s expansive authority under the Dodd-Frank Act. Yet, as the CFPB has reshaped much of the financial regulatory landscape, it has had an eager and willing partner in state attorneys general offices (AGs), each of which has its own independent UDAP authority. This double whammy of UDAAP-UDAP enforcement, from not just one federal regulator, but from a collection of state AGs across the country, is a major part of the post-financial crisis focus on consumer protection. As the financial services industry awaits news of the future of the CFPB, the states already are ramping up their efforts to ensure they are ready to fill any void left by potential reform at the CFPB.

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Originally published in Law360; reprinted with permission.

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