Can Recent Enforcement Actions Provide Guidance On The CFPB’s Position On UDAAPs?
FDCPA Defense
MARCH 2, 2014
But how can a collector know exactly what the CFPB will consider to be an “unfair” or “deceptive” or “abusive” collection practice? The CFPB has provided some guidance on UDAAPs in the bulletin it released in July 2013 and in the Examination Manual that it published in 2012. NCO also agreed to judgment for a civil penalty totaling $3.2
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