UDAAP Compliance Under CFPB Director Chopra Pt. 1

06/14/22 • 16 min

COMPLY: The Marketing Compliance Podcast

Today’s podcast is a discussion between Rhonda McGill, Sr. Director of Client Solutions at PerformLine and Tony Alexis, Partner at Goodwin Law and former Assistant Director and Head of the Office of Enforcement at the CFPB, where he developed and managed the CFPB’s enforcement strategy, consumer financial investigations and litigation. During today’s podcast they discuss UDAAP compliance under CFPB Director Chopra, specifically:

The recision of the CFPB's guidance on Abusiveness Standard in 2020 and how it impacts organizations today
The recent update to the UDAAP examination manual to include discrimination under "unfair"
The recent notable UDAAP enforcement actions
And the CFPB's crackdown on repeat offenders and how that ties into UDAAP

The recision of the CFPB's guidance on Abusiveness Standard in 2020 and how it impacts organizations today
The recent update to the UDAAP examination manual to include discrimination under "unfair"
The recent notable UDAAP enforcement actions
And the CFPB's crackdown on repeat offenders and how that ties into UDAAP

Previous Episode

Comply Now, Don’t Pay Later

Today’s podcast is discussion had between John Zanzarella, VP of Sales here at PerformLine and Eamonn Moran, Of Counsel at Morgan, Lewis & Bockius LLP. Their conversation revolves around the implications of the CFPB's recent probe into five major BNPL providers - which was announced last December and was due on March 1st of this year - over concerns about risks to consumers associated with accumulating debt, regulatory arbitrage, credit reporting, and data harvesting. As well as what compliance or legal teams at buy now, pay later companies can proactively put in place today to adhere to existing regulations for consumer finance products including UDAAP and TILA.

Next Episode

UDAAP Compliance Under CFPB Director Chopra. Pt. 2

Today’s podcast is part two of a discussion had between Rhonda McGill, Sr. Director of Client Solutions at PerformLine and Tony Alexis, Partner at Goodwin Law and former Assistant Director and Head of the Office of Enforcement at the CFPB, where he developed and managed the CFPB’s enforcement strategy, consumer financial investigations and litigation. On today’s show Rhonda and Tony continue their discussion of UDAAP Compliance Under CFPB Director Chopra, specifically:

The CFPB's updated procedural rules that provide them with the authority to carry out enforcement actions in-house
Expectations on the States' enforcement of UDAAP
The role of a strong Compliance Management System (CMS) in UDAAP compliance

COMPLY: The Marketing Compliance Podcast - UDAAP Compliance Under CFPB Director Chopra Pt. 1

Transcript

Speaker 100:00:09.330

Hello comply podcast listeners. Today's podcast is a discussion between Ronda McGill, senior director of client solutions at perform line and Tony Alexis partner at Goodwin law and former assistant director and head of the office of enforcement at the CFPB where he developed and managed the CFP B's enforcement strategy, consumer financial investigations and litigation. During today's podcast, I discussed UDAP compliance under CFPB director Chopra