On July 10, 2013, the Consumer Financial Protection Bureau (CFPB) issued two bulletins that directly affect all consumer lenders and creditors that are subject to the Dodd-Frank Act.
Bulletin 2013-07 puts creditors on notice that unfair, deceptive or abusive acts or practices (UDAAPs) are a violation of the Dodd-Frank Act. The effect of this notice is to extend the same rigorous requirements to original creditors that the Fair Debt Collection Practices Act (FDCPA) currently imposes only on third party debt collectors. The bulletin contains general descriptions and examples of conduct that the CFPB considers to be UDAAP’s.
Originally Published in Missouri Independent Bankers Association Director's Supplement - October 2013.
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