Please check out the latest edition of our UDAAP Round-Up — a periodic review of federal activities regarding the prohibition on unfair, deceptive, or abusive acts or practices (“UDAAPs”) in the consumer financial services space. In this edition, we cover notable policy, enforcement, and supervisory developments from October 2022 through March 2023
Federal Trade Commission (FTC)
UDAAP Round-Up
US CFPB Says Hiding Negative Reviews Violates UDAAP Rules
On March 22, 2022, the US Consumer Financial Protection Bureau (CFPB) released a compliance bulletin on “Unfair and Deceptive Acts or Practices That Impede Consumer Reviews.” The bulletin announced that the CFPB would view practices that discourage or hide consumer reviews as unfair or deceptive practices under Sections 1031 and 1036 of the Consumer Financial…
US FTC Holds Its First Open Meeting of 2022: What Happened?
By Christopher B. Leach on
On January 20, 2022, the FTC continued its recent experiment in holding open meetings of its commissioners. The FTC did not vote on new initiatives; Chair Lina Khan is likely waiting for a third Democratic commissioner before pushing through her more controversial agenda. Public comments focused on two areas: possible anticompetitive conduct in the franchise…
US FTC Succeeds in First Expanded Use of Gramm-Leach-Bliley Penalty Authority
By Christopher B. Leach on
Just into the new year, the FTC notched its first success in a creative theory to extend its monetary penalty authorities, which the Supreme Court trimmed back last year. In FTC v. RCG Advances, the FTC settled allegations that a small-business financing firm and its principals violated Section 521(a) of the Gramm-Leach-Bliley Act. Originally…