Erin Jane Illman Quoted in Compliance Week Regarding CFPB’s ‘UDAPP’ Approach
Financial Services Litigation and Compliance attorney Erin Jane Illman was quoted in Compliance Week regarding Consumer Financial Protection Bureau’s (CFPB) “unfair or deceptive acts or practices” (UDAPP) approach as an ambiguous compliance concern causing financial firms a lot of trouble.
"UDAAP is based on the perspective of a 'reasonable' consumer, therefore if several customers complain and allege misrepresentations or misunderstandings, those complaints may provide a window into the perspective of the reasonable consumer. When customers repeatedly complain about an organization's product or service, the organization may want to flag those issues for further review," said Illman.
Read the complete article, “CFPB’s ‘UDAAP’ Approach Is an Ambiguous Compliance Concern,” which first appeared in Compliance Week on July 14, 2015.