Skip to main content

  • AddRemove
  • Build a Report 
Legal Update

The US Consumer Financial Protection Bureau’s “Abusive” Standard — Early Lessons

12 February 2015
Mayer Brown Legal Update
The Dodd-Frank Act granted the US Consumer Financial Protection Bureau the authority to combat “unfair, deceptive, or abusive” practices in the consumer finance industry. While the meaning of “unfair” and “deceptive” acts is reasonably clear, the definition of “abusive” remains, in the words of CFPB Director Richard Cordray, “a little bit of a puzzle.” Moreover, the guidance that the CFPB has published contributes only the quixotic advisory that the definitions of unfair, deceptive and abusive acts are separate yet overlapping. We review the handful of enforcement actions brought by the CFPB alleging abusive practices, seeking clues to understand the evolving “abusiveness” standard.


  • Reginald R. Goeke
    T +1 202 263 3241
  • Catherine A. Bernard
    US Litigation Professional Support Lawyer
    T +1 202 263 3405
  • Jeffrey H. Redfern
    T +1 202 263 3246

The Build a Report feature requires the use of cookies to function properly.  Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently.  If you do not accept cookies, this function will not work.  For more information please see our Privacy Policy

You have no pages selected. Please select pages to email then resubmit.