WASHINGTON—CUNA has joined with other five other national trade organizations in expressing concern over the Consumer Financial Protection Bureau’s statement on abusive acts or policies, including alleged deviations from statutory requirements and what the groups say is a failure to provide clear guidance regarding abusive acts or practices.
At issue are questions related to UDAAP.
“Responsible providers already take steps to identify and avoid practices that may be unfair, deceptive or abusive, and federally-regulated financial institutions have extensive compliance management systems specifically to monitor for such conduct,” the letter reads. “By identifying conduct that may be abusive because it is more egregious than conduct that is solely unfair or deceptive, the Bureau will enable institutions to better calibrate compliance systems, change practices, and better protect consumers.”
Additional Points Raised
Among other points made in the letter:
- “Abusive acts or practices are distinct from unfair or deceptive acts or practices. Certain key factors are critical in distinguishing the two.”
- Material interference requires different—and more egregious—actions than deceptive acts or practices
- The Statement does not “accord with the statutory language or fully account for the Bureau’s prior rulemaking or enforcement history” in distinguishing between a “reasonable advantage” and an “unreasonable advantage”
Joining CUNA in signing the 27-page letter were the American Financial Services Association, Bank Policy Institute, Consumer Bankers Association, Mortgage Bankers Association, and the U.S. Chamber of Commerce Center for Capital Markets Competitiveness.
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