Minimizing UDAAP Risks for Consumer Financial Services

Lessons From CFPB Enforcement Actions and Other UDAP Litigation

Recording of a 90-minute premium CLE webinar with Q&A

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Conducted on Tuesday, August 13, 2013

Recorded event now available

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Course Materials

This CLE course will review UDAAP standards and potential application to consumer financial services and products, analyze lessons learned from recent enforcement actions—particularly the aggressive action by the CFPB—and impart best practices for financial services companies to minimize UDAAP risks.


UDAAP poses grave challenges for financial services companies. The addition of the “abusive” standard for prohibited consumer practices is largely undefined and vague and there is little guidance on how the UDAAP standards will be applied to various consumer services and products.

In the past year, the CFPB has filed five UDAAP enforcement actions targeting credit card companies and a credit monitoring company. One action was filed against a third-party service provider indicating that financial services companies should be concerned with practices of their outside vendors.

In May 2013, the CFPB filed its first lawsuit against a debt settlement service that has since settled. These consent orders and settlement provide a roadmap of CFPB strategies with "lessons learned" for financial services companies. They also indicate a rather aggressive approach by the agency.

Listen as our authoritative panel of financial services attorneys guides you through the UDAAP standards, discusses potential application of the standards to consumer financial products and services, analyzes recent UDAAP and UDAP enforcement actions and lessons learned from consent orders and settlements, and reviews best practices to mitigate UDAAP risks.



  1. Analysis of UDAAP standards and their potential application to products and services
  2. Analysis of CFPB enforcement actions
  3. Other regulatory and state AG actions
  4. Best practices for minimizing UDAAP risks and claims


The panel will review these and other key questions:

  • How will the CFPB interpret the new “abusive” prong of UDAAP violations?
  • How might UDAAP standards be applied to various consumer financial products and services?
  • What lessons can be learned from recent CFPB consent orders and settlement of UDAAP enforcement actions and litigation?
  • What are best practices that financial services companies can take to minimize UDAAP risks?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Karla L. Reyerson
Karla L. Reyerson

Fredrikson & Byron

She focuses her practice on advising banks and other financial institutions regarding regulatory matters, including...  |  Read More

Kathlyn L. Farrell
Kathlyn L. Farrell

Managing Director
Treliant Risk Advisors

She has worked in the field of regulatory compliance for financial institutions for over 30 years and is a licensed...  |  Read More

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