Removing Barriers Blog

CFPB Hosts UDAAP Symposium
Posted June 26, 2019 by CUNA Advocacy

Yesterday, the CFPB hosted the first of a planned series of symposia focused on topics in consumer financial protection.  The symposium focused on defining “abusive” under Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act.  Representatives from CUNA and the Maryland & DC Credit Union Association were in attendance.  

The symposia featured remarks from Director Kathy Kraninger and Deputy Director Brian Johnson, as well as comments from legal and academic experts. In general, the conversation focused on the statutory history of “abusive”, the role of cost-benefit analysis, and whether behavioral economics can play a role in determining abusive behavior. 

This symposium featured two panels of UDAAP experts: the first panel featured prominent academics discussing various policy issues related to the abusive standard under Dodd-Frank and the second panel featured legal experts examining how the abusive standard has been used in practice.

Under Acting Director Mick Mulvaney, the CFPB announced an intent to end the practice of “regulation through enforcement” and engage in an effort to properly define “abusive.”  Director Kraninger has noted this issue is still a priority for the Bureau and yesterday symposium is the beginning of a process toward that goal.  CUNA has been supportive of these efforts.