On June 25, the Consumer Financial Protection Bureau (CFPB) will host the first symposium of a series it announced back in April. This inaugural symposium will focus on unfair, deceptive, or abusive acts and practices (UDAAP).

According to the CFPB, the Federal Trade Commission (FTC) has substantially defined the terms “unfair” and “deceptive” over the years. However, the term “abusive” in UDAAP is still elusive and unclear. The symposium will aim to provide clarity, as promised by Former Acting Director Mick Mulvaney during remarks at the Mortgage Bankers Association’s annual conference in October 2018.

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The agenda for the event indicates that both Director Kathleen Kraninger and Deputy-Director Brian Johnson will provide remarks. The symposium will contain two panels, one related to policy issues related to the “abusive” standard and the other about abusiveness in practice. A moderated discussion will follow both panels.

The June 25 symposium, which runs from 9 AM to 12:20 PM Eastern, will be available via live stream for those who cannot attend in person. Registration for both the live stream and in-person attendance is available on the CFPB’s website.

insideARM Perspective

The CFPB has, for the most part, held to its word that it intends to provide rules of the road to covered entities. The recently released Notice of Proposed Rulemaking provides comprehensive instruction to debt collectors, specifically about how to bring the industry into the 21st century in regards to modern communication channels. This first symposium takes a step towards providing clarity on a term that everyone knows and uses, but is not as substantively defined as its related terms of “unfair” and “deceptive.” Mark your calendars, folks, this should be a good one to watch.


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