UDAAP

UDAAP

Unfair, Deceptive, Abusive Acts or Practices

This regulation protects consumers againstunfair, deceptive, & abusive acts or practices that could:

Cause significant financial injury to consumers

Erode consumer confidence

Undermine the financial marketplace.

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The standard for unfairness in the Dodd-Frank Act is that an act or practice is unfair when: ​

It causes or is likely to cause substantial injury, such as monetary harm, to consumers ​

The injury is not unreasonably avoidable by consumers – for example, modifying or withholding information regarding pricing or fees after the member has committed to a product.​

The injury is not outweighed by countervailing benefits to consumers or to competition.​

An abusive act or practice materially interferes with the ability of the consumer to understand a term or condition of a consumer financial product or service.​

Consumer complaints play a key role in the detection of these unfair, deceptive, or abusive practices or acts.

As an MSR, make sure you are careful and detailed when you are reporting a complaint in CRM.

This will allow our ETRACS team to investigate if it might be a violation of UDAAP.​​

Ent MSRs and lenders are to be fully transparent in all interactions with members, disclosing any fees or associated costs. ​​