On March 16, 2022, the CFPB published a press release announcing its updated examination manual (click here) that includes examinations for violations involving UDAAPs (Dodd-Frank Act, Title X, Subtitle C, Sec. 1032 -1036; PL 111-203 (July 21, 2010)).


As an overview of examinations for violations involving UDAAPs, the updated examination manual states:


“As examiners review products or services, such as deposit products or lending activities, they generally should identify the risks of harm to consumers that are particular to those activities. Examiners also should review products that combine features and terms in a manner that can increase the difficulty of consumer understanding of the overall costs or risks of the product and the potential harm to the consumer associated with the product.


Full Memorandum