CFPB Releases Updated Exam Manual for UDAAPs

The updated exam manual for UDAAPs focuses on supervisory operations related to discrimination in financial markets.

03/28/2022 2:30 P.M.

1.5 minute read

The Consumer Financial Protection Bureau has published an updated exam manual for evaluating Unfair, Deceptive and Abusive Acts or Practices (UDAAPs).

These examination procedures provide general guidance, according to the CFPB, on:

  • The principles of unfairness, deception, and abuse in the context of offering and providing consumer financial products and services.
  • Assessing the risk that an institution’s practices may be unfair, deceptive, or abusive.
  • Identifying unfair, deceptive or abusive acts or practices (including by providing examples of potentially unfair or deceptive acts and practices).
  • Understanding the interplay between unfair, deceptive, or abusive acts or practices and other consumer protection and antidiscrimination statutes.

The changes in the exam manual focus on supervisory operations to better protect families and communities from illegal discrimination, including in situations where fair lending laws may not apply, according to the CFPB.

The CFPB will examine these operations for discrimination in all consumer finance markets, including credit, servicing, collections, consumer reporting, payments, remittances, and deposits. CFPB examiners will require supervised companies to show their processes for assessing risks and discriminatory outcomes, including documentation of customer demographics and the impact of products and fees on different demographic groups. The CFPB will look at how companies test and monitor their decision-making processes for unfair discrimination, as well as discrimination under Equal Credit Opportunity Act.

Read the complete exam procedures on UDAAP here and find more information on ACA’s education website, including on-demand recordings of Core Courses.

The CFPB also recently updated its debt collection examination procedures to reflect requirements for regulated entities under Regulation F, ACA International previously reported. These procedures include guidance for examination of all aspects of debt collection.

If you have executive leadership updates or other member news to share with ACA, contact our communications department at [email protected]. View our publications page for more information and our news submission guidelines here.

This site uses cookies. By continuing to use our site, you are agreeing to our use of cookies. Review our Privacy Policy for more information. You may change your preferences on how cookies are stored by reviewing the settings on your browser.

The content on this site is presented for educational, general reference, and informational purposes only; is not intended to serve as legal or other advice; is not intended to be a full and exhaustive explanation of the law in any area; and should not replace the advice of your own legal counsel. By continuing to use our site, you are agreeing to the legal disclaimers in our Terms of Use. Review our Terms of Use for more information.

Friendly Reminder

Get continued access to ACA International’s wide array of resources, which can help you become more profitable, compliant and successful.

Renew your membership today to take advantage of tools you won’t find anywhere else:

  • Discounts on seminars, products, services and events
  • Resources to strengthen your compliance department
  • Industry-specific risk management products and services
  • Participation in ACA’s online community, The Hub
    Members-only website content
  • Professional development and training opportunities, and so much more!