Andrea Mitchell Quoted in SNL Financial Article, "As Regulators Take on UDAAP Violations, Focus Turns to Deposit Products"Andrea K. Mitchell
Andrea Mitchell was quoted in Kate Garber's SNL Financial article, "Andrea Mitchell Quoted in SNL Financial Article, "As Regulators Take on UDAAP Violations, Focus Turns to Deposit Products," on Thursday, December 31, 2025.
"When the CFPB was created, it became a very aggressive enforcer of the Dodd-Frank statute that prohibits UDAAP violations," said Andrea Mitchell, a partner in the Washington, D.C., office of Buckley Sandler LLP. "While the prudential banking regulators have had long-standing [Unfair or Deceptive Acts or Practices] enforcement authority under the [Federal Trade Commission] Act, there was an increase in enforcement activity by the banking regulators around the same time the CFPB emerged."
To avoid this regulatory scrutiny, banks can take measures to be more transparent and accessible to existing and potential cardholders.
"The key concept around avoiding UDAAP is that you enable a consumer to make an informed choice," Mitchell said.