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Over the past four installments of this series, we have taken a quick look at how the consumer financial services industry ended up with a new regulator, the Consumer Financial Protection Bureau (CFPB). This new regulator is enforcing a set of new standards—unfair, deceptive or abusive acts or practices (UDAAP)—under a new statute, the Dodd-Frank Wall Street Reform and Consumer Protection Act. We examined the standards themselves and found that “unfair” is rife with subjectivity; “deceptive” does not require intent; and “abusive” is a largely a big unknown.

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