"CFPB revises UDAAP manual to include discriminatory practices" by Sasha Leonhardt, Jeffrey P. Naimon, and John R. Coleman (The Banking Law Journal)
The Banking Law JournalSasha Leonhardt, Jeffrey P. Naimon, John R. Coleman
The Consumer Financial Protection Bureau (“CFPB”) has announced significant revisions to its Unfair, Deceptive, or Abusive Acts or Practices (“UDAAP”) exam manual, in particular highlighting the CFPB’s view that its broad authority under UDAAP allows it to address discriminatory conduct in the offering of any financial product or service.
Congress has enacted several statutes that outlaw discrimination on specified prohibited bases, including the Equal Credit Opportunity Act (“ECOA”), which generally makes it unlawful to discriminate on a prohibited basis when extending credit and which the CFPB is authorized to enforce.
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