Credit unions can comment on the CFPB’s latest guidance that addresses “abusive conduct” in consumer financial markets.
The guidance includes a policy statement that aims to assist consumer financial protection enforcers in identifying wrongdoing and help firms avoid committing abusive acts or practices.
The guidance states that abusive conduct generally includes obscuring important features of a product or service or leveraging certain circumstances — including gaps in understanding, unequal bargaining power, or consumer reliance — to take unreasonable advantage. Specifically, the guidance describes how the use of “dark patterns, set-up-to-fail business models like those observed before the mortgage crisis, profiteering off captive customers, and kickbacks and self-dealing can be abusive,” according to the CFPB.
While policy statements provide background information about laws the CFPB administers and articulate how the CFPB will exercise its authorities, they do not impose new legal requirements. The policy statement will be published in the Federal Register and comments will be accepted until July 3, 2023.