Bank Law Monitor

Bank Law Monitor

A Legal Blog for the Financial Services Industry

Category Archives: UDAAP

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Beware: Data Breaches May Expose You to UDAP Liability

By Brian Sniffen and Faye Ricci on Posted in CFPB, Cybersecurity, Regulatory Developments, Trending News, UDAAP
Recently, the U.S. Court of Appeals for the Third Circuit ruled that the Federal Trade Commission (FTC) may pursue a lawsuit against Wyndham Worldwide Corporation, a hotel and time share operator for “unfair and deceptive” cybersecurity practices. In its complaint, the FTC alleged that Wyndham “unreasonably and unnecessarily” exposed consumers’ personal data in more than… Continue Reading

CFPB Expands Its Jurisdiction to Include Nonbank Auto Finance Companies

By Faye Ricci on Posted in Auto Finance, CFPB, TILA/RESPA, UDAAP, Uncategorized
On June 10, 2015, the CFPB published a rule that will allow the agency to supervise nonbank auto finance companies that make, acquire or refinance 10,000 or more loans or leases a year. This rule was originally proposed in September 2014 and is the fifth in a series of rulemakings to define larger participants of markets… Continue Reading

CFPB Fines PayPal $25 Million for Violations of UDAAP

By Faye Ricci on Posted in CFPB, Regulatory Developments, UDAAP
On May 19, 2015, the CFPB announced that it was filing a complaint and proposed consent order in federal court against PayPal, Inc., based on allegations that PayPal Credit (fka “Bill Me Later”), had violated the prohibition against unfair, deceptive, abusive acts and practices (UDAAP).  This filing is noteworthy for two reasons. First, it was… Continue Reading

CFPB Pursuing Mortgage Servicers with UDAAP

By Faye Ricci on Posted in CFPB, Mortgage Servicing, Regulatory Developments, UDAAP
On September 29, 2014, the CFPB took action against Flagstar Bank for violating the CFPB’s new mortgage servicing rules by “illegally blocking borrowers’ attempts to save their homes.” The CFPB focused on the Flagstar’s actions from 2011 to present and found that Flagstar failed to devote sufficient resources to administering loss mitigation programs for distressed… Continue Reading

Welcome to Bank Law Monitor: A Legal Blog for the Financial Services Industry

By Graham & Dunn on Posted in Auto Finance, CFPB, Compliance Resources, Credit Cards, Debt Collection, Marijuana, Mortgage Servicing, Overdrafts, Regulation AB, Regulatory Developments, TILA/RESPA, Trending News, UDAAP
Welcome! Graham & Dunn’s Financial Services team is pleased to announce the launch of Bank Law Monitor, a legal blog for the financial services industry. Bank Law Monitor will analyze regulatory developments, report on significant news and market trends, and monitor upcoming regulatory changes that impact the financial services industry. Our goal is to help… Continue Reading