Evaluate products and practices against the CFPB’s UDAAP framework (Unfair, Deceptive, Abusive Acts or Practices) under Dodd-Frank Section 1031. Scores Unfairness, Deception, and Abusiveness dimensions with weighted risk flags and recommended controls.
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Scope & reliance — Scoring logic is based on published CFPB examination procedures, enforcement patterns, and supervisory guidance current as of 2025. Risk scores are illustrative outputs — they do not replace a formal legal or compliance review. Verify thresholds and guidance citations against current primary sources before relying on outputs for regulatory submissions or enforcement defense.
Product & Market Context
Pricing & Fee Transparency (Unfairness Factors)
Marketing & Communications (Deception Factors)
Marketing deception analysis incorporates pricing and fee transparency signals above. A claim that omits material cost information can meet the CFPB’s deceptive standard even if technically accurate.
Abusiveness under CFPB’s April 2023 Policy Statement includes “unreasonably tak[ing] advantage of” a consumer’s lack of understanding, inability to protect their own interests, or reasonable reliance on the covered person.
Risk Flags Triggered
Recommended Controls
Control
UDAAP Dimension
Priority
Regulatory Basis
Priority Remediation Actions
Regulatory Citations
Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1031 (12 U.S.C. § 5531) — CFPB authority to prohibit unfair, deceptive, or abusive acts or practices by covered persons and service providers.
CFPB Examination Procedures: UDAAP, March 2022 — examiner guidance defining substantial injury, reasonable avoidability, and countervailing benefits tests for unfairness; material representation tests for deception.
CFPB Supervisory Highlights, various editions (2012–2024) — documented UDAAP enforcement patterns across deposit accounts, credit cards, prepaid products, and digital payment services.
FTC Act Section 5 (15 U.S.C. § 45) — unfair or deceptive acts or practices; parallel authority applied by the FTC and referenced by CFPB for non-bank covered persons.
CFPB Policy Statement on Abusive Acts or Practices, April 2023 — clarified the “unreasonably takes advantage of” standard and enforcement posture, including stand-alone abusiveness claims.