States Begin to Use UDAAP Provision in Enforcement Actions

Last week, the head of the New York Department of Financial Services (DFS) became the first state regulator to use his authority under Dodd-Frank Section 1042 to bring a civil action for a violation of its prohibition of unfair, deceptive, or abusive acts or practices (UDAAP). Just last month, the Illinois Attorney General became the first state attorney general to file a state court lawsuit under this section of the law. DFS Superintendent Benjamin Lawsky filed his complaint in New York federal court against a large subprime auto lender and <more>