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“Abusive” behavior, is it obvious or subjective?

Question: 
In terms of UDAAP, what makes something “Abusive”?
Answer: 

Generally, an “abusive” practice is one that materially makes it difficult to understand terms or conditions of a consumer product or service. This may be seen in connection with inaccurate marketing materials or poorly written disclosures. It is also a practice that may mislead someone about the risks or costs or conditions of a product or service you offer. There is no bright line test and there is subjectivity in the interpretation.

Learn more about Andy’s webinar UDAAP Reality Check.

First published on 05/08/2016

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