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UDAAP Consumer Financial Protection Bureau (CFPB) 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

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Nondiscrimination and Military Protection Law

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2024 applicable to consumers protected by nondiscrimination and military protection laws. 2025 will likely bring more of the same, particularly in the area of...more

Hudson Cook, LLP

CFPB Bites of the Month - August 2024 - All That's Left of the CFPB's Summer Sky

Hudson Cook, LLP on

In this month's article, we share some of our top "bites" for the prior and current month covered during the August 2024 webinar....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

Sheppard Mullin Richter & Hampton LLP

Texas Court Strikes Down CFPB UDAAP Policy

On September 8, a Texas federal judge ruled that the CFPB exceeded its authority by adopting a sweeping anti-discrimination policy last year. The CFPB adopted the policy in March 2022, via an update to its exam manual,...more

Davis Wright Tremaine LLP

May 2023 UDAAP Bulletin

The following document provides a monthly roundup summarizing enforcement actions, guidance, rulemakings, and other public statements from the Consumer Financial Protection Bureau and the Federal Trade Commission regarding...more

Bradley Arant Boult Cummings LLP

We Wish You a Happy Thanksgiving as We Count Our Blessings

As we all hit the grocery store for that forgotten cranberry sauce and send a few last urgent work emails, we hope everyone is able to be with friends and family this Thanksgiving. Here at Bradley, we are counting our...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

Sheppard Mullin Richter & Hampton LLP

Industry Groups to CFPB: Take Back UDAAP Anti-Discrimination Policy

On June 28, the American Bankers Association, Consumer Bankers Association, Independent Community Bankers of America, and the U.S. Chamber of Commerce affirmed in a letter to CFPB Director Rohit Chopra that the CFPB should...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

Troutman Pepper Locke

CFPB Massively Expands Enforcement of Anti-Discrimination Through UDAAP

Troutman Pepper Locke on

On March 16, the Consumer Financial Protection Bureau (CFPB or Bureau) unveiled an enormous change to its fair lending philosophy that will have major ramifications for financial services providers of all types. In a press...more

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