Can Recent Enforcement Actions Provide Guidance On The CFPB’s Position On UDAAPs?
FDCPA Defense
MARCH 2, 2014
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. See CFPB Bulletin 2013-07, July 10, 2013, Prohibition of Unfair, Deceptive, or Abusive Acts or Practices In The Collection Of Consumer Debts, at p. f/k/a NCO Group, Inc. (“NCO”).
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