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Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Update


Understand the scope of UDAAP authority and learn practical solutions you can take to reduce the risk of becoming the CFPB's next enforcement target.

Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) continues to be a primary area of focus for regulators. Violations range from several different product types along with varying types of violations. This material will provide an overview of UDAAP along with the genesis of the rule, provide specific examples of types of UDAAP violations, restitution amounts over time, along with the outlook of UDAAP. You should leave with a strong background on the rule and how regulators have used this rule to cite different violations and enforcement actions.



Michael Canale

Michael Canale


  • Extensive experience across consumer finance including auto finance, mortgage, credit cards, student loans, and deposits
  • Specializes in operations and strategy, risk and compliance, and technology enablement
  • Works with clients on operational and compliance assessments, development and implementation of target operating models, enforcement actions and remediation, new product development, and technology integration
  • Engagements have included experience with the CFPB, OCC, and the DOJ
Vincent Urbancic, CFA

Vincent Urbancic, CFA


  • 20 years of professional experience working with financial institutions to address their most critical issues
  • Experience spans risk, compliance, and analytics for products such as mortgage, auto, credit card, student lending, and commercial lending, and has included implementing programs and leading teams of senior managers, managers, and consultants serving both bank and non-bank entities
  • Served as the independent consultant for enforcement actions, authoring reports to both the DOJ and CFPB as to the adequacy and effectiveness of remediation activities
  • Led dozens of evaluations on fair lending/servicing for a variety of products such as mortgage, auto, credit cards, student, and commercial

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