Client Alert

UDAP Crackdown A Closer Look at the UDAP Analysis Underlying New Credit Card Rules

January 29, 2009

V. Gerard Comizio, Chris Daniel, Lawrence D. Kaplan, Kevin L. Petrasic, Azba Habib and Helen Y. Lee

The Board of Governors of the Federal Reserve System (Board), the Office of Thrift Supervision (OTS), and the National Credit Union Administration (NCUA) (collectively, the Agencies) recently issued a joint, final rule (UDAP Regulations) under Section 5 of the Federal Trade Commission Act (FTC Act) that provides clarification to the body of law surrounding unfair or deceptive acts or practices (UDAPs). In adopting the regulations, the Agencies exercised specific authority granted to them under Section 18(f) of the FTC Act to prevent unfair or deceptive acts or practices engaged in by banks, savings associations, and Federal credit unions (collectively, the Banks).

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