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The CFPB recently announced that it is updating its exam manual to direct its examiners to consider discriminatory conduct an “unfair” act or practice represents a significant expansion of its UDAAP authority. We discuss: the CFPB’s legal theory; types of products/services/bases for discrimination the CFPB could reach using unfairness and role of disparate impact analysis; what manual updates tell examiners to ask about and look at; implications for entities the CFPB does not supervise or have jurisdiction over; likely legal challenges to the Bureau’s theory; and how companies can prepare.
Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation, joined by John Culhane and Ron Vaske, partners in the firm’s Consumer Financial Services Group, and Heather Klein, Of Counsel in the Group.
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