April 12, 2022

NAFCU updates UDAAP issue brief to highlight CFPB revised examination procedure guide

cfpb NAFCU Friday updated its unfair, deceptive, or abusive acts or practices (UDAAP) issue brief to reflect the CFPB’s recently revised examination procedure guide for UDAAP. This revision specifies that the agency will now target discrimination as an “unfair” practice in connection with all financial products and services and not just credit products.

Of note, the updated brief notes that while the bureau has yet to explicitly discuss what types of discrimination are covered under the CFPB’s new stance, it appears that the bureau may begin engaging in disparate impact enforcements. Credit unions may wish to begin looking at their policies, practices, and procedures for noncredit financial products and services to assess their UDAAP risk under this recent guidance.

Read the UDAAP issue brief. NAFCU developed the issue brief to help credit unions understand the regulatory landscape and enforcement expectations under the bureau's authority. The association will continue to highlight the importance of clear regulatory guidance and expectations as credit unions work to provide their members with safe, affordable financial products and services.