Page 72 - Pay Magazine s2014
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Government watch
CFPB’s Enforcement Lessons for the Payments Industry
UDAAP claims have appeared in the vast majority of the CFPB’s enforcement actions, including 81% of actions led in 2016.
uDaap vs. non-uDaap
90%
80%
70%
60% 48% 52% 50%
75%
75%
81%*
19%*
40% 30% 20% 10%
0%
25%
25%
2013
2014
2015
2016
*as of July 1
n UdAAp n NoN-UdAAp
uDaap: litigateD actions vs. settleD actions
30
25
20
15
10
3
30
15
5 0
2013 2014 2015 2016
*as of July 1
2013 2014 2015 2016
*as of July 1
litigAtEd ACtioNs
sEttlEd ACtioNs
12
9 9*
4*
10
Most of the CFPB’s UDAAP actions continue to be resolved through settlements rather than contested litigation.
Number of Cases
