"This article reviews the history of UDAP from its antitrust origins to today's consumer protection focus, and outlines the Federal Trade Commission's test for unfair trade practices. The authors believe UDAP's history is not yet entirely written and that the CFPB will increasingly apply UDAP law in the consumer protection arena. To prepare for renewed UDAP enforcement, consumer financial service providers must make knowledge of, and compliance with these laws, their highest priority."
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