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The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) empowers the Consumer Financial Protection Bureau (CFPB) to prohibit unfair, deceptive or abusive acts or practices (UDAAP). Abusive acts or practices under Dodd-Frank are those that:

1. materially interfere with the ability of a consumer to understand a term or condition of a consumer financial product or service; or

2. take unreasonable advantage of: a lack of understanding on the part of the consumer of the material risks, costs, or conditions of the product or service; the inability of the consumer to protect the interests of the consumer in selecting or using a consumer financial product or service; or the reasonable reliance by the consumer on a covered person to act in the interests of the consumer.

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