UDAAP

Financial institutions that are regulated and supervised by the Office of the Comptroller of the Currency (OCC) should know that the OCC has recently updated its booklet on Unfair or Deceptive Acts or Practices (UDAP) and Unfair, Deceptive, or Abusive Acts or Practices.

As anyone who is associated with the residential real estate settlement services industry can appreciate, resolution of the <EM>PHH</EM> case by the full bench of the D.C. Circuit Court of Appeals has brought much-needed clarity and reason to fundamental issues under the Real Estate Settlement Procedures Act (RESPA).

A recent settlement of deceptive practice allegations against Peoples Bank of Lawrence, Kansas, by the Board of Governors of the Federal Reserve System serves as a reminder that unfair or deceptive acts or practices (UDAP) claims may be triggered based on perceived inconsistencies between representations a consumer financial services institution makes to consumers and its actual practices.

Every week, courts around the United States issue decisions addressing aspects of civil UDAAP claims. In an effort to illuminate the UDAAP standards, below is a sampling of some of this week’s UDAAP decisions on the meaning of unfair, deceptive, and abusive.

Every week, courts around the United States issue decisions addressing aspects of civil UDAAP claims. In an effort to illuminate the UDAAP standards, below is a sampling of some of this week’s UDAAP decisions on the meaning of unfair, deceptive, and abusive.

Every week, courts around the United States issue decisions addressing aspects of civil UDAAP claims. In an effort to illuminate the UDAAP standards, below is a sampling of some of this week’s UDAAP decisions on the meaning of unfair, deceptive, and abusive.

Every week, courts around the United States issue decisions addressing aspects of civil UDAAP claims. In an effort to illuminate the UDAAP standards, below is a sampling of some of this week’s UDAAP decisions on the meaning of unfair, deceptive, and abusive.