What is an unfair, deceptive, or abusive act or practice?
7/1/2019 11:00 AM
The accounts receivable management industry is awash with an alphabet soup of confusing—but very important—acronyms you must be mindful of in your daily work. The Dodd-Frank Wall Street Reform and Consumer Protection Act granted the Consumer Financial Protection Bureau the ability to identify and prohibit unfair, deceptive or abusive acts and practices (UDAAPs).
While the CFPB doesn’t publish a specific list of actions that fall into these “unfair, deceptive or abusive” categories, we do have some examples of conduct the bureau has found to be a violation. Your agency should have policies and procedures in place to prevent these actions, but it’s still helpful to review them.
Read Understanding UDAAPs in Collector magazine for examples of practices to avoid.
Many of these unfair, deceptive or abusive actions are of course already prohibited under the Fair Debt Collection Practices Act, which means that agencies can be liable under both acts for violations. All the more reason to stick to your agency’s policies and procedures and follow any scripts you are provided.
The CFPB is also reviewing policy development on UDAAPs and whether it should further define “abusive acts or practices” after a panel discussion June 25.
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