News & Analysis as of

UDAAP Consumer Financial Products Anti-Discrimination Policies

Ballard Spahr LLP

Is There Legal Authority for Trump’s “Debanking” Executive Order?

Ballard Spahr LLP on

As we previously reported, on August 7, 2025, President Trump issued an Executive Order (the “EO”) titled “Guaranteeing Fair Banking for All Americans” which, among other things...more

Jones Day

Federal Court Rejects CFPB's Novel Use of "Unfair, Deceptive, or Abusive Acts or Practices" Authority

Jones Day on

Ruling concludes "unfairness" authority under the Dodd-Frank Act does not cover discrimination. On September 8, 2023, a federal district court rejected the Consumer Financial Protection Bureau's ("CFPB") interpretation...more

Eversheds Sutherland (US) LLP

Focus on Fintech: CFPB plans to use its UDAAP authority to expand its anti-discrimination efforts to non-credit financial products...

The CFPB recently updated  its examination manual to, in Director Chopra’s words, “combat discriminatory practices across the board in consumer finance.” Under the CFPB’s revised manual, any discriminatory conduct that the...more

BCLP

CFPB Redefines Discrimination in Financial Services with Updates to UDAAP Examination Manual

BCLP on

The Consumer Financial Protection Bureau (CFPB) materially altered the consumer protection landscape in the financial services industry through a series of revisions to its examination manual for unfair, deceptive and abusive...more

Buchalter

CFPB Expands the Consumer Financial Products It Will Examine for Potential Discrimination Issues; Intends to Include All Financial...

Buchalter on

On March 16, 2022, the CFPB announced it will expand the scope of its enforcement activities regarding discrimination beyond the specific areas covered by ECOA, by applying the UDAAP unfair practices standard to...more

WilmerHale

CFPB Announces Expansion of Unfairness Analysis to Address Discrimination

WilmerHale on

On March 16, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) announced a significant expansion of its “anti-discrimination efforts to combat discriminatory practices across the board in consumer finance.” Under...more

Perkins Coie

CFPB Announces Expanded Anti-Discrimination Efforts Through UDAAP

Perkins Coie on

Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra warned consumer finance companies that he will be expanding the bureau’s anti-discrimination efforts “to combat discriminatory practices across the board in...more

Saul Ewing LLP

CFPB's Use of its UDAAP Authority to Address Illegal Discrimination

Saul Ewing LLP on

CFPB's intended use of its UDAAP authority to investigate, and regulate and enforce against illegal "discrimination" in financial products and services breaks open the proverbial damn, with such authority washing over every...more

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