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UDAAP. Is it appropriate for the CFPB to use its enforcement authority to signal, on a case by-case basis, which practices it believes to be
UDAAP. Is it appropriate for the CFPB to use its enforcement authority to signal, on a case by-case basis, which practices it believes to be unfair, deceptive, or abusive? Do you think that the CFPB should only define such practices through notice and comment rulemaking? What challenges might this approach pose for the financial sector?
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